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Greenline Manufacturing, Inc., a VAT-registered taxpayer, receives a Final Assessment Notice (FAN) for 2024 indicating a VAT deficiency of ₱3,500,000. The FAN states the tax type (VAT), the year (2024), the amount due, and the deficiency reason (input-output mismatch) but does not include a computation schedule or supporting data. On the same day, a separate Collection Demand directs payment of ₱3,500,000 within 15 days; the Collection Demand states the tax type, the period, and the amount due but expressly notes that the period and the basis are “consistent with FAN” and provides only a single-line computation instead of a full schedule. Five days later, BIR levies the taxpayer’s corporate bank account to satisfy the amount. The taxpayer argues the levy is void for lack of essential requisites. (a)Identify the requisites of a valid final assessment under the NIRC and the requisites of a valid collection demand. (b)Distinguish, with brief rationale, the controlling rule that makes a levy valid when all requisites are present versus invalid when any requisite is missing. (c)Apply to the facts and determine whether the levy is proper, and outline Greenline’s possible remedies.

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Clara

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