Practice question
A taxpayer merely requests reconsideration based on existing records. No reinvestigation is granted and no estoppel or other suspension ground exists. May the BIR automatically treat the request as the granted-reinvestigation suspension?
- Yes; every letter suspends time forever.
- Yes; taxpayer correspondence abolishes prescription.
- Yes; a denied request necessarily equals a granted reinvestigation.
- No; those distinct conditions have not been established.
- No; because 223 contains no suspension grounds at all.
Legal references
- NIRC Sections204,206-208,222-223 and248-249, as applicable and amended: https://lawphil.net/statutes/repacts/ra1997/ra_8424_1997.html
- BPI v. CIR, G.R.139736, October17,2005, MAIN decision: https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/1/41647
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