Practice question
A notice states that an attached form supplies the payment due date, but the form’s due-date field is blank and no other definite deadline appears. What defect follows Fitness By Design?
- The missing definite payment demand is not supplied by the reference to an unaccomplished enclosure
- A reference automatically fills every blank
- The taxpayer must invent its own deadline
- Any computation date necessarily becomes the payment deadline
- Blank fields are conclusive proof of a valid demand
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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