Practice question
An officer establishes the numerical substantial-underdeclaration predicate and calls it irrebuttable proof of fraud, refusing to consider material rebuttal evidence. The taxpayer does not deny that the statutory prima facie rule is relevant. Which is correct?
- Prima facie expressly means no evidence may ever rebut it.
- Prima facie is not synonymous with irrebuttable; material rebuttal cannot be rejected merely by changing that evidentiary label.
- The predicate automatically proves payment instead.
- The statutory rule can never have evidentiary force.
- Only a tax receipt's paper color decides falsity.
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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