Practice question
A nonfraud tax offense is already filed in court, while a different nonfraud offense remains unfiled. Explain why they cannot simply be bundled into one automatically authorized administrative compromise.
Legal references
- NIRC Sections204,206-208,222-223 and248-249, as applicable and amended: https://lawphil.net/statutes/repacts/ra1997/ra_8424_1997.html
- BIR RMC46-99, extrajudicial compromise of criminal tax violations: https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/10/47959
- RA11976 Sections41 and45, EOPT surcharge and specified concessions: https://lawphil.net/statutes/repacts/ra2024/ra_11976_2024.html
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