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Essay Multiple Choice

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All Jurisprudence based

0 tracked cards Commercial and Taxation Laws

A lender's records show transactions of a partnership. The BIR assesses individuals on the same amounts without reliable proof that they personally earned or received the taxable income, and alleges fraud merely because the partnership did not report the sums. The individuals timely contest the assessment. Which analysis follows Magaan?

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An allegation eliminates the need for facts The BIR must establish the factual link to the assessed taxpayers and cannot infer personal taxable income and fraud solely from unsupported attribution Fraud is presumed from every bookkeeping discrepancy Separate taxpayer identity is irrelevant

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