Practice question
Under the implementing rule discussed in Citysuper, does the sixty-day supporting-document period apply to a true request for reconsideration based on existing records?
- Yes, because the two protest forms are always identical
- Yes, even if no additional evidence is contemplated
- No; the rule expressly distinguishes requests for reconsideration
- No, because reconsideration is never a valid protest
- Only if the taxpayer pays the officer personally
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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