Practice question
The taxpayer denies receiving the FAN. The BIR offers only an internal log entry listing the taxpayer and a mailing number, with no independent service evidence. What is the problem identified in Villanueva?
- An internal entry alone does not establish actual receipt through competent independent proof
- A log number conclusively proves receipt in every case
- The denial makes service irrelevant
- An unmailed notice is always sufficient
- The taxpayer’s silence before receipt establishes delivery
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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