Practice question
The BIR files a collection complaint after the applicable ordinary period and points only to earlier repeated demand letters. No warrant was served, qualifying suit filed, or other legally sufficient collection step taken in time; no suspension exists. Which is best?
- Every repeated letter necessarily restarts time forever.
- Demand correspondence alone cannot automatically substitute for the required timely qualifying collection commencement.
- Any unsigned office note is always equivalent to a filed suit.
- Finality makes all collection chronology irrelevant.
- The taxpayer must prove that time never passes.
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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