Gancayco vs.

Collector
Gancyaco files his income tax return for the year 1949. Respondent issued a warrant of distraint and levy
against the properties of Gancayco for the satisfaction of his deficiency income tax liability, and
accordingly, the municipal treasurer issued a notice of sale of said property at public auction. Gancayco
filed a petition to cancel the sale and direct that the same be re-advertised at a future date

ISSUE: Whether the sum of PhP 16,860.31 is due from Gancayco as deficiency income tax for 1949
hinges on the validity of his claim for deduction:
a) farming expense PhP 27,459
b) representation expenses PhP 8,933.45

HELD:
a)Farming Expenses - no evidence has been presnted as to the nature of the said farming expenses
other than the care statement of petitioner that they were spent for the development and cultivation of his
property.

No specification has been made as to the actual amount spent for purchase of tools, equipment or
materials or the amount spent for improvement.

b) Representation expense
PhP 22, 820 is allowed
PhP 8,993.45 is disallowed because of the absence of recipt, invoices or vouchers of the expenditures in
question, petitioner could not sspecify the items constituting the same when or on whom or on what they
were incurred.