Practice question
The CIR properly establishes the applicable substantial-underdeclaration presumption and discloses its computation and invocation of ten years. The taxpayer then successfully rebuts the presumption by proving inadvertence. The CIR offers no independent sufficient proof of deliberate falsity or intent to evade, and no other exception applies. What follows under Villanueva?
- The presumption is irrebuttable
- The overturned presumption alone no longer supports the extraordinary period
- The threshold automatically proves a criminal conviction
- The taxpayer’s evidence is always irrelevant
- The ordinary period has been abolished
Legal references
- CIR v. Villanueva, G.R. 249540, February 28, 2024, main decision: https://lawphil.net/judjuris/juri2024/feb2024/gr_249540_2024.html
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