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Essay Multiple Choice

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All Jurisprudence based

0 tracked cards Commercial and Taxation Laws

An ordinary valid assessment was mailed more than three years before the BIR first commenced any qualifying collection proceeding. Assume no extraordinary assessment ground, valid extension, or suspension. Can the BIR defeat prescription solely by asserting a universal five-year collection period?

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No. QL Development applies the ordinary three-year collection period on these facts. Yes, because ordinary assessments never prescribe. No, because every assessment expires after one week. Yes, because mailing never starts collection prescription.

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