Practice question
An ordinary valid assessment was timely issued, but no qualifying collection proceeding begins until after its applicable ordinary collection period. No waiver, extension, suspension or estoppel exists. The government invokes assessment finality alone. What does QL Development require?
- Examine collection prescription independently; finality does not make the collection period indefinite.
- Finality automatically creates eternal collection power.
- No collection period can apply after any assessment.
- The taxpayer's silence supplies a perpetual written waiver.
- Only penalties prescribe while principal never does.
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
Answer this question in flashcards to review your response and continue practicing.