Practice question
After one denied Division MR, a taxpayer files a prohibited second MR and assumes it automatically preserves appellate time indefinitely. No exception or court authorization applies. Which is correct?
- The rule does not permit using a second MR as an automatic endless extension device
- Every second MR necessarily tolls all periods
- Changing its caption guarantees tolling
- The tax case becomes exempt from finality
- The taxpayer can select its own appellate deadline
Legal references
- Revised CTA Rules: https://lawphil.net/courts/supreme/am/am_05_11_07_cta_2005.html Rules8,15 and16.
- 2008 CTA Rules amendments: https://lawphil.net/courts/supreme/am/am_05_11_07_cta_2008.html current amended structure.
- RA9282 amending RA1125: https://lawphil.net/statutes/repacts/ra2004/ra_9282_2004.html Sections18–19.
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