Practice question
A party files an admittedly pro forma Division reconsideration motion and calculates its En Banc deadline as if the motion suspended appeal. No exceptional relief applies. What is correct?
- Every paper suspends appeal
- A pro forma motion extends the period indefinitely
- Only the title of the paper matters
- The motion does not toll the period merely because it was labeled reconsideration
- No appeal deadline exists
Legal references
- Revised Rules of the Court of Tax Appeals, A.M. No. 05-11-07-CTA, Rules 8, 9, 15 and 16: https://lawphil.net/courts/supreme/am/am_05_11_07_cta_2005.html
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