Practice question
A corporate PAN is personally handed to a guard whose authority to receive tax notices is not established. The BIR relies only on the guard’s presence at the building. What is the proper concern?
- Every person on site is conclusively the taxpayer
- The guard’s age controls
- Tax notices need never reach anyone
- A building address alone proves authority
- Proper service and authorized receipt must be established rather than assumed from presence
Legal references
- CIR v. Fort 1 Global City Center, Inc., G.R. No. 263811, November 26, 2024, main decision: https://lawphil.net/judjuris/juri2024/nov2024/gr_263811_2024.html
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