Practice question
A taxpayer requests suspension in its CTA petition and supports it with affidavits and documents. The CIR insists the CTA has no suspension power at any stage of an appeal. Which is correct?
- Section11 expressly authorizes suspension at any stage upon the governing conditions
- The CIR’s categorical denial is correct
- Only final judgments may ever address collection
- The taxpayer’s motion automatically grants relief
- Documents eliminate the need for adjudication
Legal references
- RA1125 Section11 as amended by RA9282 Section9: https://lawphil.net/statutes/repacts/ra2004/ra_9282_2004.html
- CIR v. CTA Second Division and American Wire, GR280165, main ruling on suspension and hearing: https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/1/70104
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