Practice question
A valid CIR final denial is issued January 1 but validly received January 20. The taxpayer appeals February 5, with no special counting issue. Can the appeal be rejected solely because more than thirty days passed from issuance?
- Yes, issuance always controls
- Yes, every January decision expires January 31
- Only the tax amount matters
- No; the statutory receipt-based period must be applied
- No deadline can ever apply
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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