Practice question
The CTA grants a properly supported suspension after hearing both sides and requires security. The taxpayer says this necessarily decides that no tax is due. Which is correct?
- Suspension is always final cancellation
- Interim suspension does not itself decide ultimate tax liability
- Posting security is a final acquittal
- A hearing on suspension automatically replaces the merits trial
- Every disputed tax is extinguished by a motion
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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