Practice question
Can the ordinary finality rule be invoked to dispense with the statutory requirement that an assessment state its factual and legal bases?
- Yes, due process is always optional
- Yes, an unexplained number is always enough
- Yes, every official letter is valid
- Yes, if the taxpayer owes some other tax
- No; validity and statutory due process remain threshold requirements
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.