Practice question
A FAN was validly received. Within thirty days the taxpayer sends a letter saying only that counsel will review the matter later and requesting an indefinite extension, without validly contesting the assessment in the required manner. It argues that any correspondence automatically constitutes the statutory protest. Which answer is best?
- Every letter is legally identical to a protest
- A request for indefinite time automatically suspends the statute
- Only the envelope color determines validity
- Timely delivery alone is insufficient if the communication does not satisfy the requirements of a valid protest
- The taxpayer can choose a deadline after collection begins
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
- Level Up v. CIR, GR272354, September29 2025, main decision: https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/1/70267
Answer this question in flashcards to review your response and continue practicing.