Flashcards Studio

In Bacolod City, Delta Ventures, a taxpayer, receives a notice of local business tax assessment for 2024 totaling PHP 5,250,000 on the basis of alleged misclassification under the city's tax schedule. The taxpayer files a petition for review with the Court of Tax Appeals challenging the assessment and, at the same time, asks the trial court for a temporary restraining order to suspend collection of the tax while the case is pending. The city treasurer opposes, claiming there is no statutory basis to suspend collection except by proper court order. The trial court grants the TRO for 45 days upon posting of a bond. (a) Identify the central doctrine governing suspension of tax collection and the standard for its grant. (b) Distinguish suspension of collection from mere postponement or collection under protest. (c) Apply the doctrine to the facts and determine whether the court properly granted the TRO, with brief justification.