Practice question
Counsel prepares a timely notice of appeal from a covered RTC original criminal judgment but files it only at the BIR and serves nobody. He relies on satisfying the number of days. What is the defect?
- No defect exists if the date is early
- Timeliness alone does not satisfy filing in the rendering court and service on the adverse party
- The notice must instead be sent only to a newspaper
- Only the tax amount matters
- Service is prohibited
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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