Practice question
After a criminal tax information is filed, the taxpayer receives an adverse decision on its disputed assessment. It assumes its own assessment appeal was automatically filed with the criminal case. What does Mendez explain?
- Every taxpayer appeal is automatically included
- No taxpayer may contest an assessment
- The criminal information is the taxpayer’s petition
- The BIR must withdraw every notice
- The government’s recovery is included, but the taxpayer must separately preserve its assessment remedies
Legal references
- People v. Mendez, G.R. Nos. 208310-11 and 208662, March 28, 2023, main en banc decision, prosecution guidelines: https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/1/69095
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