After a Bureau of Internal Revenue (BIR) audit, V Corp., a domestic corporation engaged in buying and selling of scrap metals, was found to have deciency income tax of R25,000,000.00, including interests and penalties, for the year 2012. For 2012, V Corp. led its income tax return (E) on April 15, 2013 because it used the calendar year for its accounting. The BIR sent the Preliminary Assessment Notice (PAN) on December 23, 2015, and eventually, the Final Assessment Notice (FAN) on April 11, 2016, which were received by V Corp. on the same dates that they were sent. Upon receipt of the FAN, V Corp. led its protest letter on June 25, 2016. Thereafter, and without action from the Commissioner of Internal Revenue (CIR), V Corp. led a petition for review before the Court of Tax Appeals, alleging that the assessment has prescribed. For its part, the CIR moved to dismiss the case, pointing out that the assessment had already become nal because the protest was led beyond the allowable penod. A. Is V Corp.'s contention regarding the prescription of the assessment meritorious? Explain. B. Should the CIR's motion to dismiss be granted? Explain