Practice question
The BIR seeks additional disputed tax through a civil action and argues that choosing a judicial remedy makes assessment and prescription requirements irrelevant in every case. No particular exception has been established. Which is the best analysis?
- The broad claim fails; the governing prerequisites and prescription must be examined, including any actually applicable statutory exception.
- Civil actions always eliminate all tax-law limitations.
- Every civil complaint automatically proves the tax due.
- The court must ignore all defenses because revenue is important.
- The taxpayer's mere objection conclusively cancels all tax.
Legal references
- NIRC Sections205,220 and222(a); https://lawphil.net/statutes/repacts/ra1997/ra_8424_1997.html
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