10. After due proceedings, the Bureau of Internal Revenue (BIR) issued a Final Notice and Assessment with Final Letter of Demand assessing Kotse Corp. for deficiency income taxes covering calendar year 2021, which Kotse Corp. duly protested. A month after receipt of the protest, the Commissioner of Internal Revenue issued a notice of garnishment against Kotse Corp.’s deposit accounts in GENZ Bank. If you were counsel for Kotse Corp., what advice would you give to secure an injunction against the notice of garnishment? Explain briefly. (5 points)