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Philippine Bar review · Question

Practice question: Notice of Discrepancy

Multiple Choice Hard

Practice question

A taxpayer attends a discrepancy discussion, disagrees with the findings, and signs accurate minutes acknowledging what was discussed. The examiner claims that signature alone conclusively accepts every proposed tax and waives later remedies. No settlement or waiver was executed. Which is correct?
  1. Signing the discussion record alone does not transform it into acceptance of a final assessment or an express waiver
  2. Every signature on minutes is a compromise
  3. Minutes automatically become an enforceable FAN
  4. Disagreement becomes legally impossible after attendance
  5. The signature transfers tax liabilities to the representative

Legal references

  • BIR RMO1-2026, SectionIX(B)–(C), page12: https://bir-cdn.bir.gov.ph/BIR/pdf/RMO%20No.%201-2026.pdf

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