Practice question
A taxpayer files a CTA appeal from an assessment decision and immediately orders its bank to disregard a lawful collection measure solely because the appeal is pending. No suspension order exists. Which analysis is correct?
- Every pending appeal is a suspension order
- A bank may grant tax injunctions
- Filing alone does not suspend collection; the taxpayer must seek appropriate CTA relief under the statutory conditions
- The appeal automatically pays the tax
- The taxpayer unilaterally controls all enforcement
Legal references
- RA9282 amending RA1125, Sections7,11 and18–19: https://lawphil.net/statutes/repacts/ra2004/ra_9282_2004.html
- Revised CTA Rules, Rules4,8,10,15–16: https://lawphil.net/courts/supreme/am/am_05_11_07_cta_2005.html
- 2008 amendments to CTA Rules: https://lawphil.net/courts/supreme/am/am_05_11_07_cta_2008.html
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