Review Note
Last Update: 03/27/2025 11:26 AM
Current Deck: Y2S2::TAX LAW I::1 - Intro
PublishedCurrently Published Content
Front
What is the rule on estoppel? Is the rule absolute?
Back
The state CANNOT be estopped from collecting taxes due to the mistakes or errors of its agents.
But this rule is NOT absolute. In China Banking v. CIR, the BIR took 12 years to collect the tax and the taxpayer raised the defense of prescription upon appeal - but the State did NOT question the timeliness of the defense, hence, they are bound.
But this rule is NOT absolute. In China Banking v. CIR, the BIR took 12 years to collect the tax and the taxpayer raised the defense of prescription upon appeal - but the State did NOT question the timeliness of the defense, hence, they are bound.
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