Practice question
A taxpayer repeatedly induces postponement of collection through positive assurances on which the government reasonably relies. The BIR invokes the exceptional estoppel principle discussed in BPI, supported by those facts. Which is best?
- Every taxpayer letter necessarily establishes estoppel.
- Examine the established inducement and reliance; absence of an ordinary granted-reinvestigation ground does not automatically resolve exceptional estoppel.
- Estoppel is identical to a written waiver in all respects.
- Finality alone makes all collection timeless.
- The taxpayer's conduct can never matter under BPI.
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
Answer this question in flashcards to review your response and continue practicing.