Practice question
A taxpayer seeks ordinary RTC restraint of BIR collection and argues the words declaratory relief in its caption alone evade Section218. The substance is solely restraint of national tax collection. Which is correct?
- The label alone does not avoid the statutory collection restriction or create special CTA authority in the RTC
- Any caption overrides the statute
- Declaratory relief always transfers CTA powers
- Every civil action automatically stays tax collection
- A label permanently exempts the taxpayer
Legal references
- NIRC: https://lawphil.net/statutes/repacts/ra1997/ra_8424_1997.html Section218.
- RA9282 amending RA1125: https://lawphil.net/statutes/repacts/ra2004/ra_9282_2004.html special CTA suspension authority.
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