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Philippine Bar review · Question

Practice question: Suspension and Waiver of Prescriptive Period

Essay Medium Jurisprudence

Practice question

Distinguish a binding legal injunction against collection from a taxpayer’s request that the BIR voluntarily defer collection while reviewing a protest. Explain the Section223 consequence.

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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