Week 10

III. IN CASE OF DENIAL OF PROTEST OR INACTION, APPEAL TO CTA

A. Scope of Jurisdiction of CTA/What is Appealable to CTA
Sec. 4, 2nd par., NIRC Sec. 228, NIRC
Sec. 7, Rep. Act No. 1125, as amended by Rep. Act No. 9282

CIR v. Villa, 22 SCRA 4 (1968)

Facts: Villa and his wife filed joint income tax returns for the years 1951-1956. Subsequently,
the BIR determined the income of the spouses by the use of networth method and accordingly
issued on 23 February 1961 assessments for deficiency income tax for the years 1951-1954
and 1956 and residence tax for 1951-1957. Dr. Villa received the assessments on 7 April 1961.
Without contesting the said assessments in the BIR, he filed on 4 May 1961 a petition for review
in the Court of Tax Appeals

The Court of Tax Appeals took cognizance of the appeal, tried the case on the merits and
reversed the decision of the BIR. From said judgment, the Commissioner of Internal Revenue
appealed the decision, hence the petition.

Issue: Whether or not the Court of Tax Appeals had jurisdiction to entertain the appeal of the
taxpayer

Ruling: No. The law uses the word "decisions", not "assessments", thus further indicating the
legislative intention to subject to judicial review the decision of the Commissioner on the protest
against an assessment but not the assessment itself.

Since in the case at bar the taxpayer appealed from the assessment of the Commissioner of
Internal Revenue without previously contesting the same, the appeal was premature and the
Court of Tax Appeals had no jurisdiction to entertain said appeal. For, as stated, the jurisdiction
of the Tax Court is to review by appeal decisions of the Commissioner of Internal Revenue on
disputed assessments.

A. Application of 180-day Rule

Sec. 3(a)(2), Rule 4 and Sec. 3(a), Rule 8, Revised Rules of the CTA (S.C.
A.M. No. 05-11-07-CTA, Nov. 22, 2005)

Lascona Land Co., Inc. v. CIR, CTA Case No. 5777, Jan. 4, 2000

Facts: On 27 March 1998, the CIR issued an assessment against LLC for alleged deficiency
income tax, surcharge, interest and compromise penalty for the year 1993, resulting from the
disallowance of certain items claimed by LLC as deductions from its gross income specially
taxes and licenses and interest expense. LLC received a copy of the said assessment on April
1, 1998 and protested the same on April 20, 1998.
Through a letter dated 3 March 1999 and received by LLC on 12 March 1999, CIR informed
LLC that while they agree with the arguments advanced in the latter's letter of protest, they
cannot give due course to its request to cancel or set aside the assessment notice since the
case was not elevated to the Court of Tax Appeals. This, according to CIR, rendered the
assessment notice final, executory and demandable.

Issue: Whether or not the assessment has become final, executory and demandable.

Ruling: In cases of inaction the Tax Code gave the taxpayer an option: first, he may appeal to
the Court of Tax Appeals within thirty (30) days from the lapse of the one hundred eighty (180)
day period provided for under the said section, or second, he may wait until the Commissioner
decides on his protest before he elevates his case. This Court believes that the taxpayer was
given this option so that in case his protest is not acted upon within the 180-day period, he may
be able to seek immediate relief and need not wait for an indefinite period of time for the
Commissioner to decide. But if he chooses to wait for a positive action on the part of the
Commissioner, then the same could not result in the assessment becoming final, executory and
demandable.

We agree with LLC that to adopt the interpretation of CIR will not only sanction inefficiency, but
will likewise condone the Bureau's inaction. This is especially true in the instant case when
despite the fact that CIR found LLC's arguments to be in order, the assessment will become
final, executory and demandable for LLC's failure to appeal before the CTA within the thirty (30)
day period.

Rizal Commercial Banking Corp. v. CIR, G.R. No. 168498, April 24, 2007

Facts: On 5 July 2001, RCBC received a Formal Letter of Demand dated 25 May 2001 from the
respondent CIR its tax liabilities particularly for Gross Onshore Tax and Documentary Stamp
Tax for its Special Savings Placements for the taxable year 1997. On 20 July 2001, RCBC filed
a protest letter/request for reconsideration/reinvestigation pursuant to Section 228 of the
National Internal Revenue Code of 1997 (NIRC).

As the protest was not acted upon by the CIR, RCBC filed on April 30, 2002 a petition for
review with the CTA for the cancellation of the assessments.

On 15 July 2003, CIR filed a motion to resolve first the issue of CTAs jurisdiction, which was
granted by the CTA in a Resolution dated 10 September 2003. The petition for review was
dismissed because it was filed beyond the 30-day period following the lapse of 180 days from
petitioners submission of documents in support of its protest, as provided under Section 228 of
the NIRC and Section 11 of R.A. No. 1125, otherwise known as the Law Creating the Court of
Tax Appeals.

Issue: Whether or not the CTA has jurisdiction of the case.

Ruling: In the instant case, the Commissioner failed to act on the disputed assessment within
180 days from date of submission of documents. Thus, petitioner opted to file a petition for
review before the Court of Tax Appeals. Unfortunately, the petition for review was filed out of
time, i.e., it was filed more than 30 days after the lapse of the 180-day period. Consequently, it
was dismissed by the Court of Tax Appeals for late filing. Petitioner did not file a motion for
reconsideration or make an appeal; hence the disputed assessment became final, demandable
and executory.

Based on the foregoing, petitioner can not now claim that the disputed assessment is not yet
final as it remained unacted upon by the Commissioner; that it can still await the final decision of
the Commissioner and thereafter appeal the same to the Court of Tax Appeals. This legal
maneuver cannot be countenanced. After availing the first option, i.e., filing a petition for review
which was however filed out of time, petitioner can not successfully resort to the second option,
i.e., awaiting the final decision of the Commissioner and appealing the same to the Court of Tax
Appeals, on the pretext that there is yet no final decision on the disputed assessment because
of the Commissioners inaction.

C. What Constitutes Denial of Protest/Decision on Disputed Assessment

1. General Rule
2. Issuance of Revised Assessment Upon Reinvestigation

Avon Products Mfg., Inc. v. CIR, CTA Case No. 5908, Jan. 20, 2005

Facts:
Issue:
Ruling:

3. Final Notice Before Seizure

CIR v. Isabela Cultural Corp., 361 SCRA 71 (2001)

Facts: In an investigation conducted on the 1986 books of account of ICC had the preliminary
finding that ICC incurred a total income tax deficiency of P9,985,392.15. Upon protest by ICCs
counsel, the said preliminary assessment was reduced to the amount of P325,869.44.

On 23 February 1990, ICC received from CIR an assessment letter, dated 9 February 1990,
demanding payment of the amounts of P333,196.86 and P4,897.79 as deficiency income tax
and expanded withholding tax inclusive of surcharge and interest, respectively, for the taxable
period from 1 January to 31 December 1986.

In a letter, dated March 22, 1990, filed with the CIR office on March 23, 1990, ICC requested x x
x a reconsideration of the subject assessment. Supplemental to its protest was a letter, dated
April 2, 1990, filed with the CIRs office on 18 April 1990 to which x x x were attached certain
documents supportive of its protest, as well as a Waiver of Statute of Limitation, dated 17 April
1990, where it was indicated that CIR would only have until 5 April 1991 within which to assess
and collect the taxes that may be found due from ICC after the re-investigation.

On 9 February 1995, ICC received from CIR a Final Notice Before Seizure, dated 22 December.
In said letter, CIR demanded payment of the subject assessment within ten (10) days from
receipt thereof. Otherwise, failure on its part would constrain CIR to collect the subject
assessment through summary remedies. ICC considered said final notice of seizure as CIR final
decision. Hence, the instant petition for review.

Issue: Whether or not the Final Notice Before Seizure constitutes denial of protest.

Ruling: Yes. In the light of the above facts, the Final Notice Before Seizure cannot but be
considered as the commissioners decision disposing of the request for reconsideration filed by
respondent, who received no other response to its request. Not only was the Notice the only
response received; its content and tenor supported the theory that it was the CIRs final act
regarding the request for reconsideration. The very title expressly indicated that it was a final
notice prior to seizure of property. The letter itself clearly stated that respondent was being
given this LAST OPPORTUNITY to pay; otherwise, its properties would be subjected to
distraint and levy.

4. Final Demand Letter

CIR v. Ayala Securities Corp., 70 SCRA 204 (1976)

Facts: On 29 November 1955, Ayala Securities Corporation, filed its income tax returns for its
fiscal year which ended on 30 September 1955. Attached to its income tax return was the
audited financial statements of ASC as of 30 September 1955, showing a surplus of
P2,758,442.37. The income tax due on the return of ASC was duly paid for within the time
prescribed by law.

In a letter dated 21 February 1961, CIR advised ASC of the assessment of P758,687.04 on its
accumulated surplus reflected on its income tax return for the fiscal year which ended 30
September 1955. ASC in a letter dated 19 April 1961, protested against the assessment on its
retained and accumulated surplus pertaining to the taxable year 1955 and sought
reconsideration thereof for the reasons (1) that the accumulation of the surplus was for a bona
fide business purpose and not to avoid the imposition of income tax on the individual
shareholders, and (2) that the said assessment was issued beyond the five-year prescriptive
period.

On 30 May 1961, CIR wrote ASCs auditing and accounting firm with the advise that your
request for reconsideration will be the subject matter of further reinvestigation and a thorough
analysis of the issues involved conditioned, however, upon the execution of your client of the
enclosed form for waiver of the defense of prescription. However, ASC did not execute the
requested waiver of the statute of limitations, considering its claim that the assessment in
question had already prescribed.

On 21 February 1963, ASC received a letter dated 18 February 1963, from the Chief, Manila
Examiners, of the Office of the CIR, calling the attention of the ASC to its outstanding and
unpaid tax in the amount of P758,687.04 and thereby requesting for the payment of the said
amount within five (5) days from receipt of the said letter. Believing the aforesaid letter to be a
denial of its protest, the herein respondent corporation filed with the Court of Tax Appeals a
Petition for Review of the assessment.

Issue: Whether or not the final demand letter constitutes denial of protest.

Ruling: Yes. The letter of 18 February 1963 is tantamount to a denial of the reconsideration or
protect of the respondent corporation on the assessment made by the petitioner, considering
that the said letter is in itself a reiteration of the demand by the Bureau of Internal Revenue for
the settlement of the assessment already made, and for the immediate payment of the sum of
P758,687.04 in spite of the vehement protest of the respondent corporation on 21 April 1961.
This certainly is a clear indication of the firm stand of petitioner against the reconsideration of
the disputed assessment, in view of the continued refusal of the respondent corporation to
execute the waiver of the period of limitation upon the assessment in question. This being so,
the said letter amounts to a decision on a disputed or protested assessment.

However, the Court ruled in favour of ASC on the ground of prescription of the assessment
made by the CIR. The assessment prescribed on 15 January 1961.

Surigao Electric Co. Inc. v. CTA, 57 SCRA 523 (1974)

Facts: In November 1961, SURECO, grantee of a legislative electric franchise, received a

warrant of distraint and levy to enforce the collection from "Mainit Electric" of a deficiency
franchise tax plus surcharge in the total amount of P718.59. SURECO contested this warrant,
stating that it did not have a franchise in Mainit, Surigao.

Thereafter the Commissioner, by letter dated 2 April 1961, advised the SURECO to take up the
matter with the General Auditing Office, enclosing a copy of the 4th Indorsement of the Auditor
General dated 23 November 1960. Subsequently, in a letter to the Auditor General dated 2
August 1962, SURECO asked for reconsideration of the assessment, admitting liability only for
the 2% franchise tax in accordance with its legislative franchise and not at the higher rate of 5%,
which latter rate the Auditor General used as basis in computing the SURECO's deficiency
franchise tax.

The controversy culminated in a revised assessment dated 29 April 1963 (received by the
SURECO on 8 May 1963) in the amount of P1 1,533.53, representing the SURECO's deficiency
franchise tax and surcharges thereon for the period from 1 April 1956 to 30 June 1959.
SURECO then requested a recomputation of the revised assessment in a letter to the
Commissioner dated 6 June 1963 (sent by registered mail on 7 June 1963). The Commissioner,
however, in a letter dated 28 June 1963 (received by SURECO on July 16, 1963), denied the
request for recomputation.

On 1 August 1963 the SURECO appealed to the Court of Tax Appeals. The tax court dismissed
the appeal on 1 October 1965 on the ground that the appeal was filed beyond the thirty-day
period of appeal provided by section 11 of Republic Act 1125.

Issue: Whether or not the demand letter dated 29 April 1963 constitute denial of protest.

Ruling: Yes. The letter of demand dated April 29, 1963 unquestionably constitutes the final
action taken by the Commissioner on the petitioner's several requests for reconsideration and
recomputation. In this letter, the Commissioner not only in effect demanded that the petitioner
pay the amount of P1 1,533.53 but also gave warning that in the event it failed to pay, the said
Commissioner would be constrained to enforce the collection thereof by means of the remedies
provided by law. The tenor of the letter, specifically the statement regarding the resort to legal
remedies, unmistakably indicates the final nature of the determination made by the
Commissioner of the petitioner's deficiency franchise tax liability.

Prescinding from all the foregoing, we deem it appropriate to state that the CIR always indicate
to the taxpayer in clear and unequivocal language whenever his action on an assessment
questioned by a taxpayer constitutes his final determination on the disputed assessment. On the
basis of this indicium indubitably showing that the Commissioner's communicated action is his
final decision on the contested assessment, the aggrieved taxpayer would then be able to take
recourse to the tax court at the opportune time. Without needless difficulty, the taxpayer would
be able to determine when his right to appeal to the tax court accrues. This rule of conduct
would also obviate all desire and opportunity on the part of the taxpayer to continually delay the
finality of the assessmentand, consequently, the collection of the amount demanded as
taxesby repeated requests for recomputation and reconsideration. On the part of the
Commissioner, this would encourage his office to conduct a careful and thorough study of every
questioned assessment and render a correct and definite decision thereon in the first instance.
This would also deter the Commissioner from unfairly making the taxpayer grope in the dark
and speculate as to which action constitutes the decision appealable to the tax court. Of greater
import, this rule of conduct would meet a pressing need for fair play, regularity, and orderliness
in administrative action.

5. Filing of Collection Suit

CIR v. Union Shipping Corp., 185 SCRA 547 (1990)

Facts: In a letter dated 27 December 1974, CIR assessed against Yee Fong Hong, Ltd. and/or
herein Union Shipping Corporation, the total sum of P583,155.22 as deficiency income taxes
due for the years 1971 and 1972. Said letter was received on 4 January 1975, and in a letter
dated 10 January 1975 USC protested the assessment which was received by CIR on 13
January 1975.

CIR, without ruling on the protest, issued a Warrant of Distraint and Levy, which was served on
USCs counsel, Clemente Celso, on 25 November 1976.

In a letter dated 27 November 1976, received by CIR on 29 November 1976, USC reiterated its
request for reinvestigation of the assessment and for the reconsideration of the summary
collection thru the Warrant of Distraint and Levy.

CIR, again, without acting on the request for reinvestigation and reconsideration of the Warrant
of Distraint and Levy, filed a collection suit before Branch XXI of the then CFI of Manila, against
USC. Summons in the said collection case was issued to private respondent on 28 December
1978.

On 10 January 1979, USC filed with respondent court its Petition for Review of CIRs
assessment of its deficiency income taxes in a letter dated 27 December 1974 wherein it prays
that after hearing, judgment be rendered holding that it is not liable for the payment of the
income tax herein involved, or which may be due from foreign shipowner Yee Fong Hong, Ltd.;
to which CIR filed his answer on 29 March 1979.

The Tax Court, in a decision dated 9 December 1983, ruled in favor of USC. Hence, the instant
petition.

Issues: Whether or not the filing of collection suit constitute denial of protest.

Ruling: Yes. The request for reinvestigation and reconsideration was in effect considered
denied by petitioner when the latter filed a civil suit for collection of deficiency income. So that
on January 10, 1979 when private respondent filed the appeal with the Court of Tax Appeals, it
consumed a total of only thirteen (13) days well within the thirty day period to appeal pursuant to
Section 11 of R.A. 1125.
If an individual or corporation like the petitioner in this case, is not in the actual possession,
custody, or control of the funds, it can neither be physically nor legally liable or obligated to pay
the so-called withholding tax on income claimed by Yee Fong Hong, Ltd.

6. Referral to Solicitor General for Collection

Republic v. Lim Tian Teng Sons & Co., supra

Facts:
Issue:
Ruling:
7. Issuance of Warrant of Distraint and Levy

Central Cement Corporation v. CIR, CTA Case No. 4312, Sept. 1, 1993
Facts:
Issues:
Ruling:

CIR v. Algue, Inc., 158 SCRA 9 (1988)

Facts: On 14 January 1965, Algue engaged in engineering, construction and other allied
activities, received a letter from the CIR assessing it in the total amount of P83,183.85 as
delinquency income taxes for the years 1958 and 1959. On 18 January 1965, Algue filed a letter
of protest or request for reconsideration, which letter was stamp-received on the same day in
the office of the CIR. On 12 March 1965, a warrant of distraint and levy was presented to the
Algue, through its counsel, Atty. Alberto Guevara, Jr., who refused to receive it on the ground of
the pending protest. A search of the protest in the dockets of the case proved fruitless. Atty.
Guevara produced his file copy and gave a photostat to BIR agent Ramon Reyes, who deferred
service of the warrant. On 7 April 1965, Atty. Guevara was finally informed that the BIR was not
taking any action on the protest and it was only then that he accepted the warrant of distraint
and levy earlier sought to be served. Sixteen days later, on 23 April 1965, Algue filed a petition
for review of the decision of the CIR with the Court of Tax Appeals.

Issues: Whether or not the issuance of Warrant of Distraint and Levy constitute denial of
protest.

Ruling: No. It is true that as a rule the warrant of distraint and levy is "proof of the finality of the
assessment" and "renders hopeless a request for reconsideration," being "tantamount to an
outright denial thereof and makes the said request deemed rejected." But there is a special
circumstance in the case at bar that prevents application of this accepted doctrine. The proven
fact is that four days after the private respondent received the petitioner's notice of assessment,
it filed its letter of protest. This was apparently not taken into account before the warrant of
distraint and levy was issued; indeed, such protest could not be located in the office of the
petitioner. It was only after Atty. Guevara gave the BIR a copy of the protest that it was, if at all,
considered by the tax authorities. During the intervening period, the warrant was premature and
could therefore not be served.

Advertising Associates, Inc. v. CA, 133 SCRA 765 (1984)

Facts: AAI alleged that it sold in 1949 its advertising agency business to Philippine Advertising
Counsellors, that its business is limited to the making, construction and installation of billboards
and electric signs and making and printing of posters, signs, handbills, etc.. It contends that it is
a media company, not an advertising company.

The Commissioner required Advertising Associates to pay P297,927.06 and P84,773.10 as

contractors tax for 1967-1971 and 1972, respectively, including 25% surcharge on its income
from billboards and neon signs. The basis of the assessment is the fact that the taxpayers
articles of incorporation provide that its primary purpose is to engage in general advertising
business. Its income tax returns indicate that its business was advertising.

AAI contested the assessments in its letters of 25 June 1973 (for the 1967-71 deficiency taxes)
and March 7, 1974 (for the 1972 deficiency). The Commissioner reiterated the assessments in
his letters of 12 July and 16 September 1974.

The taxpayer requested the cancellation of the assessments in its letters of 13 September and
21 November 1974. Inexplicably, for about four years there was no movement in the case.
Then, on 31 March 1978, the Commissioner resorted to the summary remedy of issuing two
warrants of distraint, directing the collection enforcement division to levy on the taxpayers
personal properties as would be sufficient to satisfy the deficiency taxes. The warrants were
served upon the taxpayer on April 18 and May 25, 1978.

More than a year later, Acting Commissioner Plana wrote a letter dated May 23, 1979 in answer
to the requests of the taxpayer for the cancellation of the assessments and the withdrawal of the
warrants of distraint. He justified the assessments by stating that the rental income of AAI from
billboards and neon signs constituted fees or compensation for its advertising services. He
requested the taxpayer to pay the deficiency taxes within ten days from receipt of the demand;
otherwise, the Bureau would enforce the warrants of distraint.

AAI received that letter on 18 June 1979. Nineteen days later or on 7 July it filed its petition for
review. The Tax Court did not resolve the case on the merits. It ruled that the warrants of
distraint were the Commissioners appealable decisions. Since AAI appealed from the decision
of May 23, 1979, the petition for review was filed out of time. It was dismissed. Hence, the
taxpayer appealed to this Court.

Issues: Whether or not the issuance of Warrant of Distraint is barred by prescription.

Ruling: No. The taxpayer received on 18 June 1973 and 5 March 1974 the deficiency
assessments herein. The warrants of distraint were served upon it on April 18 and May 25, 1978
or within five years after the assessment of the tax. Obviously, the warrants were issued to
interrupt the five-year prescriptive period. Its enforcement was not implemented because of the
pending protests of the taxpayer and its requests for withdrawal of the warrants which were
eventually resolved in Commissioner Planas letter of 23 May 1979.

D. Period to Appeal/Effect of Failure to Appeal

Sec. 228, last par., NIRC
Sec. 11, Rep. Act. No. 1125, as amended by Rep. Act. No. 9282

St. Stephens Association v. Collector of Internal Revenue, 104 Phil. 314 (1958)

Facts:
Issues:
Ruling:

Roman Catholic Archbishop of Cebu v. Collector, 4 SCRA 279 (1962)

Facts:
Issues:
Ruling:

Pantranco v. Blaquera, 107 Phil. 975 (1960)

Facts: on February 12, 1954 originally assessed and demanded from Pantranco the amount of
P73,791.66 as documentary stamp from 1948 to 30 September 1953, plus P1,000.00 as
compromise. On 4 March 1954, Pantranco requested a reinvestigation of respondent's original
assessment and demand, on the grounds that the same was arbitrary and without legal basis,
and assuming that the tax is due, that the collection of said tax has already prescribed.
Blaquera, on 16 September 1954 denied this request and urged Pantranco to pay the amount of
P66,959.32. In view of the change in the amount demanded petitioner, in a letter dated 4
October 1954, requested a clarification thereof. In reply to this letter, Blaquera on 15 November
1954 wrote a letter enclosing therewith his letter dated 16 September 1954 which shows the
result of the reinvestigation of the case and the consequent modification of the assessment from
the amount of P74,791.66 to P66,959.92. The last mentioned letter of Blaquera with the
enclosed reduced assessment was received by Pantranco on 20 November 1954. On
December 2, 1954, Pantranco sought a reconsideration of the modified assessment. In this
letter of Pantranco, which Blaquera received on 3 December 1954, it also reiterated its request
that the case be held in abeyance pending the termination of the interprovincial Autobus Co.
case.

In the meantime, the City Treasurer of Dagupan demanded from Pantranco, in a letter dated 3
January 1955, the payment of the amount of P66,959.62. On 14 January 1955 Pantranco
followed-up its request contained in the letter dated 2 December 1954. Blaquea finding that
Pantranco has not yet paid the assessment in question again demanded payment of the same
in a letter dated 21 January 1955 making no reference to Pantranco 's two letters. Hence, in a
letter dated 28 January 1955, Pantranco called the attention of Blaquera, to petitioner's letters of
December 2, 1954 and January 14, 1955 requesting that the assessment be reconsidered and
that the case be held in abeyance pending decision of the case of Interprovincial Autobus Co. In
reply to petitioner's letter, respondent in a letter dated May 28, 1955 which petitioner received
on June 11, 1955 denied the former's request. Thereafter, the present petition for review (before
the Tax Court) was filed on July 2, 1955.

Considering that the ruling or decision of the Collector of 16 September 1954 had been received
by Pantranco on 20 November 1954, the Court held that the 30-day period began to run on 20
November 1954; that it was interrupted by the petition for reconsideration filed 3 December
1954; and that such interruption ended on 11 June 1955, when denial of the reconsideration
was received by Pantranco; and finding that the petition had thus been presented on the 34th
day after receipt of the Collector's definite assessment, (November 20 to December 3-13 days;
June 11 to July 2-21 days; total 34 days) the said Court resolved to dismiss the petition.

Issues: Whether or not the period to appeal has prescribed.

Ruling: Yes. The letter of September 16, 1954 is the decision of the Collector which the
taxpayer had to contest within thirty days; otherwise, it would have become final and
unappealable to the Court of Tax Appeals, or to any other court. It was a definite determination
of Pantranco's tax accountability. Pantranco could ask for reconsideration, of course; if
successful, well and good. If unsuccessful, it must appeal within thirty days, discounting the time
within which its petition to reconsider had been pending. This computation is nothing unusual: it
is the ordinary way the timeliness of appeals is determined. The thirty-day period granted to the
taxpayer within which to contest assessments made by the Collector of Internal Revenue is
jurisdictional and non-extendible.

Basa v. Republic, 138 SCRA 34 (1985)

Facts:
Issues:
Ruling:

Mambulao Lumber Co. v. CIR, 132 SCRA 1 (1984)

Facts:
Issues:
Ruling:

E. Mode of Appeal and Effect of Appeal

1. Appeal to a Division of the CTA
Sec. 11, Rep. Act. No. 1125, as amended by Rep. Act. No. 9282

2. Appeal to CTA En Banc

Sec. 18, Rep. Act. No. 1125, as amended by Rep. Act. No. 9282
IV. APPEAL TO SUPREME COURT
Sec. 19, Rep. Act. No. 1125, as amended by Rep. Act. No. 9282