24. True.

The doctrine arose from common

law allowing offsetting of a prescribed

claim for refund against a tax liability

arising from the same transaction on

which an overpayment is made and

underpayment is due. The doctrine finds

no application to cases where the taxes

involved are totally unrelated, and

although it seems equitable, it is not

allowed in our jurisdiction (CIR v. UST,

104 Phil 1062 (1958))

https://www.lawphil.net/judjuris/juri1988/jun1988/gr_l_67649_1988.html

31. True. (CIR v. BF Goodrich., Phils. Inc.,

G.R. No. 104171, Feb. 24, 1999; Phil.

Journalists, Inc. v. CI

BIR: Prescription; Construction in

Criminal Cases (2010)

(Ib) True or False. In criminal cases

involving tax offenses punishable under the

National Internal Revenue Code (NIRC),

prescription is construed strictly against

the government. (1%)

SUGGESTED ANSWER:

False. (Lim v. Court of Ap