Practice question
An assessed taxpayer refuses payment after demand. The BIR asserts the Section 219 lien against a mortgagee before filing the notice required by that section, arguing that no protected third-party qualification can exist for government liens. Assume the mortgagee falls within the provision and no different priority rule governs. Which is correct?
- The government's assertion overrides the express qualification.
- The lien is not valid against the specified mortgagee until the statutory notice is filed.
- A mortgagee is never mentioned in the statute.
- The taxpayer may secretly waive the mortgagee's statutory protection.
- The lien becomes a local real-property tax merely because land is mortgaged.
Legal references
- NIRC Section219, Nature and Extent of Tax Lien; https://lawphil.net/statutes/repacts/ra1997/ra_8424_1997.html
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