Practice question
After apprehension, a taxpayer pays the assessed civil tax in full and obtains an ordinary receipt. The receipt contains no authorized criminal compromise, and no such agreement was made. A criminal tax charge concerns an already completed alleged violation. The taxpayer insists that the receipt necessarily extinguishes it. What is correct?
- Every receipt is a criminal acquittal
- The collector may grant unlimited immunity by silence
- Payment alone does not bar prosecution; any valid criminal settlement must be separately established within statutory authority
- Payment proves every criminal element beyond reasonable doubt
- The tax collector replaces the criminal court
Legal references
- NIRC Sections 204 and 253: https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/2/3896
- Suarez v. People, GR253429, October6 2021, main decision: https://lawphil.net/judjuris/juri2021/oct2021/gr_253429_2021.html
- BIR RMO7-2015: https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/10/69577
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