Practice question
A taxpayer files a timely current general refund claim with complete documents. The CIR issues a partial denial before 180 days. The taxpayer wants to wait until day 180 to begin counting its judicial appeal from that denial. Which is correct?
- An actual partial denial triggers the thirty-day appeal period from receipt
- Partial denial never triggers review
- Every partial denial must wait two years
- The taxpayer may select any later trigger
- Only a full denial can be appealed
Legal references
- RA11976, Sections31-32, current NIRC204(C) and229: https://lawphil.net/statutes/repacts/ra2024/ra_11976_2024.html
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