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?
- The PAN reply eliminates every later deadline
- Every preliminary reply is a permanent injunction
- The ordinary finality rule applies because the preliminary response did not automatically replace the required formal protest
- The taxpayer becomes tax-exempt
- 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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