Practice question
A corporation timely challenges a formal deficiency assessment that states only a lump-sum amount and a bare demand, with no factual or legal basis supplied in the assessment or its accompanying documents. No legally sufficient written explanation is otherwise furnished. The BIR says that a later courtroom explanation alone necessarily cures the omission. Which conclusion best follows Section 228?
- The mandatory written-basis requirement was not met; later litigation cannot simply replace the assessment-stage safeguard
- Any later lawyer argument automatically supplies all missing assessment requirements
- The taxpayer must know the basis merely because it is incorporated
- Every lump-sum demand is valid without supporting grounds
- The omission necessarily proves the taxpayer committed fraud
Legal references
- NIRC Sections6,13 and228: https://lawphil.net/statutes/repacts/ra1997/ra_8424_1997.html
- CIR v. Stradcom, G.R.255520, April21 2025: https://lawphil.net/judjuris/juri2025/apr2025/gr_255520_2025.html
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