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S1: Tax refunds are highly construed against the taxpayer because taxation is the rule and exemption is the exception. S2: A regular assessment and claim

S1: Tax refunds are highly construed against the taxpayer because taxation is the rule and exemption is the exception. S2: A regular assessment and claim for refund have the same prescriptive period. S3: Non-filing of tax return and non-payment of taxes are both considered as tax evasion. S4: The BIR has the power to inquire into bank accounts of taxpayers even without the necessary waiver from the said taxpayer. *

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