As part of its collection efforts, the Bureau of Internal Revenue (BIR) can use summary administrative remedies such as warrants of distraint and/or levy (WDLs) against delinquent taxpayers. Implementation of these presupposes that the taxpayer failed to pay the assessment despite the valid service of notices and that the assessment had attained finality and had become delinquent.

There are instances, though, where the BIR issues WDLs even though the assessment's validity remains pending in courts. This is consistent with the no injunction rule under Section 218 of the National Internal Revenue Code, as amended (Tax Code). It states that courts do not have the authority to restrain the collection of taxes imposed under the Tax Code.