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Philippine Bar review · Question

Practice question: Tax Deficiency vs. Tax Delinquency

Multiple Choice Medium

Practice question

For a current-law deficiency, full payment precedes issuance of the Commissioner's notice and demand. Which event ends deficiency interest under 249(B)?
  1. A demand issued years after full payment must always control.
  2. The tax can never stop bearing deficiency interest.
  3. Only a future criminal conviction can end it.
  4. The taxpayer's unrelated property sale.
  5. Full payment, because it is earlier.

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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