Practice question
A taxpayer disputes a claimed taxable event, supplies relevant corporate records and explains it never paid the disputed tax because no liability arose. The BIR demands a nonexistent receipt for that payment and treats its absence alone as automatic finality. On First Express-type facts, which is sound?
- The Court rejected using an impossible payment-proof demand alone to disregard the relevant records already submitted
- Every BIR document request is conclusive
- A taxpayer must invent a receipt
- No corporate record may support a tax protest
- Every denial of liability automatically proves exemption
Legal references
- CIR v. First Express Pawnshop Company, Inc., G.R. Nos. 172045-46, June 16, 2009, main decision, relevant supporting documents: https://lawphil.net/judjuris/juri2009/jun2009/gr_172045_2009.html
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