Practice question
A taxpayer validly receives an adverse final decision personally issued by the CIR and does nothing until the ordinary thirty-day CTA appeal period has expired. No exception or tolling rule applies. Does the earlier timely administrative protest alone preserve an unlimited court appeal?
- Yes, a protest preserves every appeal forever
- Yes, only the original FAN deadline matters
- Yes, if the taxpayer disagrees strongly
- No; the valid final decision triggers its own appeal period
- No, because protests are never permitted
Legal references
- NIRC Sections204,228 and229: https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/2/3896
- Lascona Land v. CIR, GR171251, March5 2012, main decision: https://lawphil.net/judjuris/juri2012/mar2012/gr_171251_2012.html
- RA9282 amending RA1125, CTA appeal provisions: https://lawphil.net/statutes/repacts/ra2004/ra_9282_2004.html
Answer this question in flashcards to review your response and continue practicing.