Practice question
A taxpayer timely elevates a representative’s denial through the allowed reconsideration route to the Commissioner. The Commissioner does not act. The taxpayer counts the administrative-appeal inaction period from a much earlier original LOA rather than the new appeal filing. Which is correct?
- The administrative-appeal paragraph uses its filing event, not audit commencement
- Every stage shares the LOA starting date
- The administrative appeal has no relevant filing date
- An audit document replaces every protest event
- The appeal is automatically granted on filing
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.
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