Practice question
After180 days of inaction, a taxpayer elects to await a decision. A later letter explicitly states it is the final decision and denies reinvestigation. The taxpayer argues the clock began only on a still later collection reminder. Which Mannasoft principle applies?
- The actual final denial’s receipt, not a later repetitive demand, is the relevant decision-based trigger
- Every collection reminder renews appeal rights
- An explicit denial is never final
- Waiting eliminates every later deadline
- Only payment can start an appeal period
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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