Practice question
A taxpayer validly receives a valid FAN, allows the thirty-day protest period to expire without a valid protest, and later seeks ordinary merits review solely because a new accountant found better expense records. No exception applies. What is the ordinary effect?
- The missed protest allows the valid assessment to become final; the new records do not automatically reopen the lost ordinary remedy
- Every new accountant restarts the deadline
- Every later record creates an automatic refund
- The taxpayer may choose any protest date
- The BIR must treat the omission as a timely protest
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
Answer this question in flashcards to review your response and continue practicing.