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Philippine Bar review · Question

Practice question: Effect of Failure to Appeal

Multiple Choice Hard

Practice question

A taxpayer receives a representative’s adverse decision and timely sends the CIR a request expressly seeking a new evidentiary reinvestigation, not the permitted reconsideration. It claims any request automatically qualifies as the administrative alternative. What does RR18-2013 require?
  1. Every new-evidence request is automatically valid elevation
  2. The administrative appeal is limited to reconsideration and issues raised in the representative’s decision; reinvestigation is not allowed
  3. No written request is needed
  4. The taxpayer may add every unrelated year
  5. Only a personal phone call is required

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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