Practice question
The government establishes a qualifying failure-to-file case under Section 222(a) and timely files a judicial collection proceeding within ten years after discovery, satisfying the other requirements. The defendant says no court suit is possible solely because no assessment preceded it. What does the express exception provide?
- No judicial collection without assessment is ever possible
- Any allegation conclusively proves liability
- Every summary seizure is authorized
- All jurisdictional requirements disappear
- The established qualifying ground permits a court collection proceeding without assessment within the stated period
Legal references
- NIRC Section 222(a): https://lawphil.net/statutes/repacts/ra1997/ra_8424_1997.html
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