Practice question
A taxpayer invokes CIR inaction as a deemed denial but identifies no Code provision fixing the relevant period of action. It relies solely on having waited an amount of time it personally considers long. Under 7(a)(2), which is best?
- Identify and satisfy the specific statutory action-period framework; subjective delay alone does not establish that category.
- Any private deadline automatically creates a deemed denial.
- Every unanswered letter creates instant CTA jurisdiction.
- Only the taxpayer's preferred calendar applies.
- Inaction is never reviewable under any provision.
Legal references
- RA9282 Section7, CTA jurisdiction: https://lawphil.net/statutes/repacts/ra2004/ra_9282_2004.html
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