Practice question
A deficiency notice quotes a tax provision but supplies no factual explanation connecting it to the taxpayer's transactions; no served attachment supplies the missing facts. The BIR argues that stating law alone necessarily satisfies Section228. Assume timely challenge and no separate issue of cure through actual written notice. Which is correct?
- The argument succeeds because facts are never required.
- The argument fails because the statute requires both law and facts in writing.
- The argument succeeds if the quoted provision is long.
- The taxpayer must invent and admit the missing facts.
- Every factual omission conclusively proves tax evasion.
Legal references
- NIRC Section228; https://lawphil.net/statutes/repacts/ra1997/ra_8424_1997.html
- CIR v. Stradcom Corporation, G.R.255520, April21 2025, main decision (assessment and lawful collection); https://lawphil.net/judjuris/juri2025/apr2025/gr_255520_2025.html
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