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Question

Subject: Doctrines in Taxation

Topic: Imprescriptibility of Taxes

Scenario:

Mr. Santos, a taxpayer, received a notice from the Bureau of Internal Revenue (BIR) stating that he has unpaid taxes from five years ago. Mr. Santos believes that the tax assessment is already barred by prescription since it has been more than three years since the tax became due.

Question:

Discuss the legal basis and implications of the doctrine of imprescriptibility of taxes in the Philippines. In the given scenario, can Mr. Santos rely on the defense of prescription? Why or why not? Support your answer with relevant laws and jurisprudence.

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Answer