Practice question
A taxpayer validly protests a FAN on the twentieth day after receipt, before the deadline and in compliance with applicable requirements. Is the protest late merely because the PAN arrived months earlier?
- Yes, all protest periods run from the PAN
- Yes, the PAN eliminated the FAN stage
- Yes, only one day is allowed
- Yes, if the auditor dislikes it
- No; the formal-assessment protest period is measured from receipt of the FAN
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.