Practice question
Auditors prepare an internal computation and recommendation for the Commissioner, but no assessment and demand is served on the taxpayer. The BIR says the internal report alone started the taxpayer’s formal protest period. Which is correct?
- Every internal report starts every taxpayer deadline
- Only the date of the auditor’s hiring matters
- A computation not properly communicated as the required assessment cannot automatically be treated as the served final demand
- The taxpayer must guess the report’s contents
- The recommendation automatically pays the tax
Legal references
- 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
- NIRC, Sections 6 and 228: https://lawphil.net/statutes/repacts/ra1997/ra_8424_1997.html
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