Practice question
An adverse final decision is received120 days after a valid protest. The taxpayer plans to appeal only after day210, relying on180 days plus thirty. No exception exists. What is wrong?
- Receipt of the actual denial triggers the decision-based appeal period instead of the unused inaction calculation
- Every denial must be ignored until day180
- The actual receipt date never matters
- All taxpayers automatically receive210 days after any filing
- The BIR can abolish review through an early decision
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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