Taxation, 2012 Bar — Question VI

QUESTION

The BIR issued in 2010 a final assessment notice and demand letter against X Corporation covering deficiency income tax for the year 2008 in the amount of P10 Million. X Corporation earlier requested the advice of a lawyer on whether or not it should file a request for reconsideration or a request for reinvestigation. The lawyer said it does not matter whether the protest files against the assessment is a request for reconsideration or a request for reinvestigation, because it has same consequences or implications. a) What are the differences between a request for reconsideration and a request for reinvestigation? (5%) b) Do you agree with the advice of the lawyer? Explain your answer (5%)

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