False vs. Fraudulent vs. Non-filed Return

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1. Absent an applicable exception, what is the ordinary NIRC assessment period under Section 203?
2. Under the Villanueva main decision, what is required beyond mere inaccuracy to invoke the extraordinary false-return pe…
3. From what event does Section 222(a) reckon its extraordinary ten-year period?
4. A return is filed before its prescribed deadline. No exception, waiver or suspension applies. How does Section 203 trea…
5. A return is filed after its prescribed deadline. No exception, waiver or suspension applies. From what date does the or…
6. An audit discrepancy is proven to be an inadvertent encoding mistake, without deliberate falsity or intent to evade. No…
7. The CIR properly establishes the applicable substantial-underdeclaration presumption and discloses its computation and …
8. Distinguish the false-return, fraudulent-return and nonfiling grounds under Section 222(a) using the current main-opini…
9. Explain the substantial-misstatement presumption’s role in invoking the extraordinary period without treating it as con…
10. Why must an assessment invoking ten years disclose the extraordinary period and its grounds rather than merely list a d…
11. Absent a sufficient presumption, what evidentiary standard does Villanueva’s MAIN guidelines place on the CIR to establ…
12. For the substantial sales-understatement presumption, the misstatement must exceed which percentage of the amount decla…