Practice question
A taxpayer's timely reinvestigation request relies on additional records contradicting alleged undeclared receipts. The BIR grants reinvestigation, receives those records and expressly evaluates them in the FDDA, but rejects them on stated grounds. The taxpayer argues that losing necessarily proves the documents were ignored. What is the best response?
- An adverse result alone does not prove nonconsideration; examine the actual evaluation, as Level Up did
- Every submitted document must automatically be accepted as true
- Every adverse FDDA is void
- Reinvestigation guarantees cancellation
- The BIR may always refuse to read timely evidence
Legal references
- NIRC Sections5–6,13 and228: https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/2/3896
- Level Up v. CIR, GR272354, September29 2025, main decision: https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/1/70267
- CIR v. CTA Third Division and Citysuper, GR239464, May10 2021, main decision: https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/1/67428
- CIR v. Standard Insurance, GR259729, November17 2025, main decision: https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/1/70327
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