Practice question
A taxpayer prepares a valid reconsideration protest relying on existing records. An officer insists that it wait sixty days to gather new evidence before filing its first protest, even though this would pass the thirty-day deadline. Which is correct?
- The valid initial protest must be timely; a later document interval is not a prerequisite delaying filing
- Every first protest must wait sixty days
- Only reinvestigation is recognized
- The auditor may privately replace all periods
- Existing-record protests have no legal role
Legal references
- NIRC Section228: https://lawphil.net/statutes/repacts/ra1997/ra_8424_1997.html
- RR18-2013 Section3.1.4: https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/10/67487 required contents of timely protest.
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