Practice question
Explain why the legal sufficiency of a Division reconsideration motion matters to a later En Banc appeal deadline.
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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