Practice question
A taxpayer receives an ordinary PAN and argues that the sixty-day supporting-document period for a FAN reinvestigation automatically replaces the PAN’s fifteen-day response period. Which is correct?
- The PAN period always becomes sixty days
- The sixty-day rule belongs to the reinvestigation protest against the FLD/FAN and does not automatically replace the PAN response period
- Every PAN is already a CBAA decision
- The taxpayer may create any deadline by labeling a letter
- A PAN requires no response opportunity
Legal references
- https://lawphil.net/statutes/repacts/ra1997/ra_8424_1997.html — NIRC, section 228
- https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/10/67487 — RR 18-2013, section 3.1.4, disputed assessments
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