Practice question
A final notice refers to April15 only as the reckoning point for additions and directs payment by the date in an enclosure. That enclosure is blank. The authority later argues the calculation reference was necessarily the payment due date. Which is correct under Fitness By Design?
- A calculation reference cannot automatically cure the omitted definite payment deadline
- Any date anywhere on the page is necessarily the deadline
- The taxpayer loses its rights by noticing the blank
- An oral date supplied years later is part of the original writing
- The enclosure’s blank proves immediate payment was expressly demanded
Legal references
- CIR v Fitness By Design GR215957 November9,2016 MAIN: https://lawphil.net/judjuris/juri2016/nov2016/gr_215957_2016.html MAIN definite tax demand and payment due date.
- CIR v Villanueva GR249540 February28,2024 MAIN: https://lawphil.net/judjuris/juri2024/feb2024/gr_249540_2024.html MAIN proof of receipt of assessment notices.
- NIRC RA8424, Sections203,222–223 and228: https://lawphil.net/statutes/repacts/ra1997/ra_8424_1997.html Section228.
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