Practice question
A timely challenged FAN has no definite payment due date on the Fitness-type facts. The BIR offers accurate arithmetic and insists accuracy necessarily cures the demand defect. Which is sound?
- Accuracy eliminates every assessment safeguard
- The taxpayer’s failure to agree creates a due date
- Only the tax’s economic importance matters
- A court must invent the omitted demand
- Arithmetic correctness does not substitute for the required definite assessment demand
Legal references
- CIR v. Fitness by Design, Inc., G.R. No. 215957, November 9, 2016, main decision: https://lawphil.net/judjuris/juri2016/nov2016/gr_215957_2016.html
- CIR v. Pascor Realty and Development Corporation, G.R. No. 128315, June 29, 1999, main decision: https://lawphil.net/judjuris/juri1999/jun1999/gr_128315_1999.html
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