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Philippine Bar review · Question

Practice question: Effect of Failure to Appeal

Multiple Choice Medium

Practice question

A taxpayer properly elevates a representative’s denial to the CIR through reconsideration on day 20. The revenue officer argues failure to file a CTA case by day 30 necessarily makes the representative’s decision final. No defect in the elevation is alleged. Which is correct?
  1. Only direct CTA filing is ever lawful
  2. Every letter to any officer prevents finality
  3. The taxpayer must wait for seizure
  4. The same subordinate alone decides the elevation
  5. The valid alternative elevation must be recognized under RR18-2013

Legal references

  • BIR RR18-2013, official digest, administrative elevation and finality: https://bir-cdn.bir.gov.ph/BIR/pdf/79052rr13_18.pdf

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