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Philippine Bar review · Question

Practice question: Period to Act Upon or Decide

Multiple Choice Hard Jurisprudence

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?
  1. The administrative-appeal paragraph uses its filing event, not audit commencement
  2. Every stage shares the LOA starting date
  3. The administrative appeal has no relevant filing date
  4. An audit document replaces every protest event
  5. 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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