Practice question
An ordinary court-collection-without-assessment period has expired. No valid extension, suspension or extraordinary ground exists. The government files later and argues that selecting a civil complaint itself revives the period. Which is correct?
- Every filing automatically resets prescription.
- The complaint's title alone removes all time limits.
- Only the court's building age matters.
- A taxpayer can never raise collection prescription.
- Changing to a civil complaint does not itself revive an expired statutory right to commence that proceeding.
Legal references
- NIRC Sections203,220,222 and253, as applicable: https://lawphil.net/statutes/repacts/ra1997/ra_8424_1997.html
- CIR v. QL Development, Inc., G.R.258947, March29,2022, MAIN: https://lawphil.net/judjuris/juri2022/mar2022/gr_258947_2022.html
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