ABC Corp. received a notice of assessment and a letter from the BIR demanding the payment of P10 million pesos in deficiency income taxes for the taxable year 2016. The financial statements of the company show that it has been suffering financial reverses from the year 2019 up to the present. Its asset position shows that it could pay only P1,500,000.00 which it offered as a compromise to the BIR. What could be a possible defense of the taxpayer for this assessment?