(2) They are correct. For criminal actions. the action prescribes 5 years from the day of the commission of the violation. But for civil actions, it is 5 years from the date of assessment.
(1) I believe that the civil action against me has already prescribed. But the BIR is insisting that it has not because only 4 years have passed since they issued the assessment.
(2) That is incorrect. Prescription will still run from the day of discovery of such violation and institution of judicial proceedings.
(1) Sir, if the day of the commission of violation of tax laws was unknown then prescription will never start to run, right?
Their right is imprescriptible as long as the period from the discovery and institution of judicial proceedings for its investigation and punishment, up to the filing of the information in court, does not exceed 5 years
(1) The government wants to collect the payment for my taxes in a criminal case. Jokes on them. Their right to collect has already prescribed!