Practice question
A taxpayer has already validly chosen and timely pursued a CTA inaction appeal. It then claims an entitlement to a second cumulative action merely because a later denial arrives. Explain the election rule without deciding case-specific pleading adjustments.
Legal references
- RR18-2013 Section3.1.4: https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/10/67487 administrative appeal limits and mutually exclusive remedies.
- Mannasoft v CIR GR244202 July10,2023 MAIN: https://lawphil.net/judjuris/juri2023/jul2023/gr_244202_2023.html MAIN warrant and election to await final decision.
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