Practice question
A taxpayer failed to file a return, and all conditions for Section 222(a)'s judicial collection without assessment are stipulated to exist, with the action timely and properly authorized. The taxpayer says every government civil tax action necessarily requires a prior deficiency assessment without exception. Which is correct?
- The taxpayer's universal statement is correct.
- The statement is too broad because Section 222(a) expressly permits the qualifying court proceeding without assessment.
- Nonfiling permanently exempts the taxpayer.
- The CIR may ignore every limitation period.
- The stipulated exception converts the case into a private arbitration.
Legal references
- NIRC Sections205,220 and222(a); https://lawphil.net/statutes/repacts/ra1997/ra_8424_1997.html
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