Practice question
A taxpayer timely files and fully pays through a channel validly permitted under current EOPT rules. No other violation exists. An officer nevertheless imposes surcharge solely by quoting the deleted pre-EOPT wrong-officer clause of 248(A). Which is best?
- The officer cannot restore the deleted standalone ground by quoting the superseded text.
- Every deleted ground remains operative forever.
- A timely full payment automatically constitutes willful fraud.
- A valid current payment channel necessarily incurs two surcharges.
- EOPT eliminated the need for any governing statute.
Legal references
- NIRC Sections204,206-208,222-223 and248-249, as applicable and amended: https://lawphil.net/statutes/repacts/ra1997/ra_8424_1997.html
- RA11976 Sections41 and45, EOPT surcharge and specified concessions: https://lawphil.net/statutes/repacts/ra2024/ra_11976_2024.html
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