Practice question
A deficiency is discovered in September for tax legally payable in April. The taxpayer says deficiency interest can start only in September because the auditor first identified it then. Which is correct?
- September necessarily replaces every statutory due date.
- Discovery always eliminates all earlier interest.
- No tax can bear interest before criminal conviction.
- Apply the prescribed payment-date rule, not an automatic audit-discovery starting date.
- Only the date of a private loan matters.
Legal references
- NIRC Sections204,206-208,222-223 and248-249, as applicable and amended: https://lawphil.net/statutes/repacts/ra1997/ra_8424_1997.html
- RA10963 Section75, amended NIRC249: https://lawphil.net/statutes/repacts/ra2017/ra_10963_2017.html
- RA11976 Sections41 and45, EOPT surcharge and specified concessions: https://lawphil.net/statutes/repacts/ra2024/ra_11976_2024.html
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