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Philippine Bar review · Question

Practice question: Effect of Failure to File Protest

Multiple Choice Hard Jurisprudence

Practice question

A company ignores a validly received valid FAN and later argues that a reply to an earlier PAN prevents finality forever. It filed no valid protest of the FAN, and no exception applies. Which consequence follows?
  1. The PAN reply eliminates every later deadline
  2. Every preliminary reply is a permanent injunction
  3. The ordinary finality rule applies because the preliminary response did not automatically replace the required formal protest
  4. The taxpayer becomes tax-exempt
  5. The collector may automatically impose imprisonment

Legal references

  • NIRC Sections5–6,13 and228: https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/2/3896
  • CIR v. CTA Third Division and Citysuper, GR239464, May10 2021, main decision: https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/1/67428
  • CIR v. Elric Auxiliary Services, GR226945, February19 2026, main decision: https://lawphil.net/judjuris/juri2026/feb2026/gr_226945_2026.html
  • CIR v. Standard Insurance, GR259729, November17 2025, main decision: https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/1/70327

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