Practice question
After valid receipt of an adverse final decision personally issued by the CIR, the taxpayer files another letter asking that same officer to reconsider. No law or applicable rule gives the letter suspensive effect, and the taxpayer misses the CTA deadline. Can the taxpayer rely on an automatic new 180-day period merely because another letter was sent?
- Yes, every repeated letter restarts every period
- Yes, correspondence always prevents finality
- No; the taxpayer cannot invent an automatic new decision period or tolling effect without a governing legal basis
- Yes, the final decision becomes a PAN
- Yes, only the taxpayer controls finality
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
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