The present case is similar to the case of Commissioner of Customs vs. Marina Sales, Inc. (G.R. No. 183868, November 22, 2010) where the Supreme…

The question

The present case is similar to the case of Commissioner of Customs vs. Marina Sales, Inc. (G.R. No. 183868, November 22, 2010) where the Supreme Court held that Rule 8, Section 1 of the Revised Rules of Court of Tax Appeals requires that “the petition for review of a decision or resolution of the Court in Division must be preceded by the filing of a timely motion for reconsideration or new trial with the Division.” The word “must” clearly indicates the mandatory, not merely directory, nature of a requirement.” A protest against an assessment issued by the Collector of Customs for unpaid customs duties on imported goods shall be filed with: (2012 Bar Question)

1. A.The Commissioner of Customs;
2. B.The Regional Trial Court;
3. C.The Court of Tax Appeals;
4. D.The Collector of Customs.

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