Practice question
For a tax period entirely after TRAIN took effect, an examiner proposes applying both deficiency and delinquency interest to the same unpaid liability for the same overlapping dates solely because an older case allowed concurrency for an earlier period. Which response is correct?
- All older decisions automatically override later statutes
- The taxpayer can choose any interest rule
- Interest becomes a voluntary donation
- The current statutory nonconcurrency rule must be respected; the historical case’s applicable period matters
- The principal tax is necessarily cancelled
Legal references
- NIRC Section249, as amended by RA10963, Section75: https://lawphil.net/statutes/repacts/ra2017/ra_10963_2017.html
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