Practice question
A proper administrative appeal is filed with the Commissioner. An unrelated duplicate reminder is sent sixty days later without a new appeal or new decision. Does the reminder automatically restart the inaction clock?
- No; the specified filing remains the starting event
- Yes, every reminder resets all periods
- Yes, a taxpayer may choose any restart date
- Yes, every copy creates a separate appeal
- Yes, the deadline is always indefinite
Legal references
- RR18-2013 Section3.1.4: https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/10/67487 original protests versus administrative appeals; decision and inaction triggers.
- Mannasoft v CIR GR244202 July10,2023 MAIN: https://lawphil.net/judjuris/juri2023/jul2023/gr_244202_2023.html MAIN final decision following election to await.
Answer this question in flashcards to review your response and continue practicing.