Practice question
An audit approaches the ordinary deadline. An officer orally asks for more time, and the taxpayer continues answering questions. No qualifying written agreement, granted reinvestigation, statutory suspension or independently established estoppel exists. The BIR asserts unlimited time based solely on cooperation. Which conclusion is strongest?
- Cooperation automatically grants unlimited time
- Oral courtesy satisfies every written-agreement rule
- Audits can never prescribe
- The asserted extension lacks an established statutory or agreed foundation on these facts
- Government deadlines are optional
Legal references
- NIRC Sections 222(b) and 223: https://lawphil.net/statutes/repacts/ra1997/ra_8424_1997.html
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