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All ▸ Bar 2024 ▸ COMMERCIAL AND TAXATION LAWS ▸ XIII. TAXATION LAW (R.A. No. 8424, as amended by R.A. No. 10963, R.A. No. 11534) ▸ F. Doctrines in Taxation ▸ 2. Construction and Interpretation of Tax Laws, Rules, and Regulations

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Mr. Reyes is a resident individual engaged in the business of selling electronic gadgets. For the taxable year 2021, Mr. Reyes received a tax assessment from the Bureau of Internal Revenue (BIR) stating that he underdeclared his income from sales by 30%. Mr. Reyes disagrees with the assessment and wants to challenge it.

In this scenario, discuss the following:

The requirements and procedure for filing an administrative protest against a tax assessment;
The remedies available to Mr. Reyes if his administrative protest is denied by the BIR;
The effect of the filing of an administrative protest on the collection of the assessed tax.

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