Practice question
A final denial is dated well before it is served. Explain the relevance of proving receipt when applying failure-to-appeal consequences.
Legal references
- NIRC Sections 204, 228 and 253, read with EOPT amendments: https://lawphil.net/statutes/repacts/ra1997/ra_8424_1997.html
- BIR RR18-2013, official digest, administrative elevation and finality: https://bir-cdn.bir.gov.ph/BIR/pdf/79052rr13_18.pdf
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