Decisions of the Collector of Customs in protest and seizure cases are appealable to the Commissioner of Customs within 15 days from receipt of…

The question

Decisions of the Collector of Customs in protest and seizure cases are appealable to the Commissioner of Customs within 15 days from receipt of notice of the written decision of the Collector. As a rule, decisions of the Collector of Customs are not appealable to the CTA. However, if the Collector does not decide a protest for a long period of time, the inaction may be considered as an adverse decision by the Collector of Customs and the aggrieved taxpayer may appeal to the CTA, even without the Collector’s and Commissioner’s actual decision. Which cases are appealable to the CTA? (2012 Bar Question)

1. A.Decisions of the Secretary of Finance in cases involving liability for customs duties, seizure, detention or release of property affected;
2. B.Decisions of the Commissioner of Customs in cases involving liability for customs duties, seizure, detention or release of property affected;
3. C.Decisions of the Collector of Customs in cases involving liability for customs duties, seizure, detention or release of property affected;
4. D.Decisions of the BIR Commissioner in cases involving liability for customs duties, seizure, detention or release of property affected.

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