Practice question
When a taxpayer properly elevates a representative’s denial administratively to the CIR, which remedy does RR18-2013 allow?
- Reconsideration, with reinvestigation disallowed on administrative appeal
- An unrestricted new reinvestigation as of right
- Only an oral complaint to a private auditor
- A new criminal trial before the treasurer
- Automatic cancellation without review
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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