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Philippine Bar review · Question

Practice question: Procedural Due Process in Tax Assessments

Multiple Choice Medium

Practice question

The BIR issues the FAN seven days after the taxpayer receives the PAN, before the fifteen-day response period expires. No exception or waiver applies. Does later opportunity to protest automatically cure the premature issuance?
  1. Yes, every later protest cures it
  2. Yes, the PAN response period is optional
  3. Only the tax amount matters
  4. No; Prime Steel rejected that substantial-compliance argument
  5. Only the invoice format matters

Legal references

  • Prime Steel Mill, Inc. v. CIR, G.R. No. 249153, September 12, 2022, main decision: https://lawphil.net/judjuris/juri2022/sep2022/gr_249153_2022.html

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