Practice question
For the distinct administrative appeal elevated to the Commissioner, RR18-2013 identifies what filing as the180-day inaction starting point?
- Filing the administrative appeal with the Commissioner
- The original LOA date
- A future invoice unrelated to the appeal
- The taxpayer’s incorporation date
- The next mayoral election
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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