Practice question
A government lawyer prepares a tax-recovery complaint governed by Section 220 but obtains no CIR approval before filing. The lawyer says preparation by counsel alone replaces the approval requirement. Which is correct?
- Counsel preparation always substitutes for CIR approval.
- Approval is required only if the taxpayer agrees.
- Approval is a newspaper-publication requirement.
- Only a bank may give the required approval.
- Counsel preparation alone does not satisfy Section 220's CIR-approval requirement.
Legal references
- NIRC Sections205,220 and222(a); https://lawphil.net/statutes/repacts/ra1997/ra_8424_1997.html
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