Practice question
A taxpayer politely asks that collection be held in abeyance while a protest is considered. No injunction, statutory bar or qualifying waiver exists. The BIR voluntarily agrees. Under Standard Insurance, is this legal prohibition under Section223?
- No; voluntary forbearance is not a legal prohibition
- Yes, every polite request legally binds the Commissioner not to collect
- Yes, administrative courtesy automatically suspends all periods
- Yes, a private letter has the force of a court injunction
- Yes, the period becomes unlimited
Legal references
- NIRC RA8424, Sections203,222–223 and228: https://lawphil.net/statutes/repacts/ra1997/ra_8424_1997.html Sections222(b) and223.
- CIR v Standard Insurance GR259729 November17,2025 MAIN: https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/1/70327 MAIN legal prohibition, definite waiver and strict suspension grounds.
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