Practice question
An additional tax was validly assessed, all review periods have ended, and the final notice and demand requires payment byJune 15. The taxpayer pays nothing by that date. Does the fact that the liability originated as a deficiency prevent delinquency treatment thereafter?
- No; an assessed deficiency unpaid by the valid demand deadline can become delinquent.
- Yes; deficiency origin permanently prevents delinquency.
- Yes; only a self-filed return can ever produce delinquency.
- No; because every preliminary audit remark is immediately delinquent.
- Yes; only the taxpayer may choose the legal classification.
Legal references
- CIR v. Stradcom Corporation, G.R.255520, April21,2025, MAIN decision: https://lawphil.net/judjuris/juri2025/apr2025/gr_255520_2025.html
- RA10963, TRAIN, amended NIRC249 deficiency/delinquency interest: https://lawphil.net/statutes/repacts/ra2017/ra_10963_2017.html
- RA11976, Ease of Paying Taxes Act, reduced interest for micro and small taxpayers: https://lawphil.net/statutes/repacts/ra2024/ra_11976_2024.html
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