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Question
DEF Corp owes deficiency income tax for 2022 in the amount of PHP 3,000,000. The Bureau of Internal Revenue (BIR) offers to compromise the civil liability: payment of PHP 2,100,000 within 20 days, in full settlement, with penalties and interest waived. DEF accepts and pays the 2,100,000. Six months later, a nationwide tax amnesty program is enacted providing a waiver of penalties and interest on all outstanding liabilities if the principal tax is paid within the amnesty period. DEF now seeks to avail of the amnesty to erase any remaining balance. (a)Identify the controlling doctrine governing compromise of civil tax liabilities and the effect of a valid compromise on the liability, including penalties and interest. (b)Distinguish how a tax amnesty operates relative to a valid compromise, and whether DEF can simultaneously or subsequently benefit from the amnesty for the same liability. (c)If the compromise is challenged as lacking formality or authority, what remedy is available to the government and/or the taxpayer, and what is the consequence if the compromise is valid and performed?