Practice question
Why cannot an undisclosed audit recommendation alone be used as the taxpayer’s receipt of a final assessment for protest deadlines?
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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