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?
- Only direct CTA filing is ever lawful
- Every letter to any officer prevents finality
- The taxpayer must wait for seizure
- The same subordinate alone decides the elevation
- 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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