COMMISSIONER V. PHILIPPINE GLOBAL (TAX)

If the PROTEST is not a request for reinvestigation, but only a request for cancellation or reconsideration of the assessment, the filing of the protest does not toll the running of the prescriptive period to collect.

BPI V. COMMISSIONER (TAX)

A REQUEST FOR REINVESTIGATION which is not granted by the Commissioner does not toll the running of the 3-year period for collection after the assessment is issued.