Challenging the merit of presumed regularity

Challenging the merit of presumed regularity

by Leah Francesca M. Castillo

challenging the merit of presumed regularity

Adjunct to the presumption of regularity in the performance of official duties is the presumption of correctness of a tax assessment. Well established is the rule in taxation that assessments are prima facie presumed correct and made in goodfaith. An assessment fixes and determines the tax liability of a taxpayer. As soon as it is served, the taxpayer concerned is supposed to be obligated to pay the amount assessed and demanded.

Although the presumption of regularity of assessments is expressed in a language superior and demanding, the power that shields an assessment is not without limits. It actually imposes a great responsibility on the tax authorities to ensure that every assessment wears the badge of credibility and due diligence.

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