Practice question
If a taxpayer specifically denies receiving a required PAN, does a bare assertion that the BIR mailed one automatically prove receipt?
- No; the BIR must establish the required service or receipt on the evidence
- Yes, assertion alone always suffices
- Only the taxpayer’s company size matters
- Receipt is irrelevant whenever tax is claimed
- The PAN need never be sent in any case
Legal references
- CIR v. Metro Star Superama, Inc., G.R. No. 185371, December 8, 2010, main decision: https://lawphil.net/judjuris/juri2010/dec2010/gr_185371_2010.html
- 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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