Practice question
A taxpayer failed to protest an assessment on time. Years later, the taxpayer raises only the separate claim that collection has prescribed. Under QL Development, does assessment finality alone conclusively bar consideration of that distinct claim?
- Yes, because collection and assessment validity are always identical.
- Yes, because a final assessment has no time limit.
- Yes, because the CTA can never consider collection prescription.
- No, because finality automatically cancels the tax.
- No. The Court distinguishes final assessment validity from collection prescription.
Legal references
- CIR v. CTA Second Division and QL Development, Inc., G.R.258947, March29 2022, main decision; https://lawphil.net/judjuris/juri2022/mar2022/gr_258947_2022.html
- NIRC Sections203 and222(c); https://lawphil.net/statutes/repacts/ra1997/ra_8424_1997.html
Answer this question in flashcards to review your response and continue practicing.