Practice question
A valid ordinary-period assessment became final. The BIR then waits twelve years to initiate any collection, with no suspension, extension or timely enforcement. It relies only on finality. What follows Standard Insurance?
- Finality alone cannot defeat an established collection-prescription defense
- Every final assessment is collectible indefinitely
- Only a taxpayer signature starts prescription
- Prescription requires an earlier merits protest
- The delay automatically proves a crime
Legal references
- RR18-2013 Section3.1.4: https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/10/67487 partial protests and undisputed issues.
- CIR v Standard Insurance GR259729 November17,2025 MAIN: https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/1/70327 MAIN void audit and collection prescription.
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