G.R. No. 115849 – 322 Phil. 280 – 252 SCRA 259 – Civil Law – Conflict of Laws – Private International Law – Origin of Forum Non Conveniens Producers Bank (now called First Philippine International Bank), which has been under conservatorship since 1984, is the owner of 6 parcels of […]
Jurisprudence
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G.R. No. L-41919-24 – 186 Phil. 604 – 97 SCRA 877 – Taxation Law – NIRC Rules of Procedure – Tax Evasion – Protest – Criminal Case Against Taxpayer May Be Filed Sans A Final Assessment In July 1974, Quirico Ungab filed his income tax return. He was subjected to […]
G.R. No. 12611 – 38 Phil. 424 – Civil Law – Obligations and Contracts – Obligations of Parties – How Extinguished – Prescription In 1897, one Anastasio Cruz incurred a P2,730.50 loan from Marcela Mariño, wife of Felipe Agoncillo. Cruz however died. Later, in February 1904, the heirs of Cruz, […]
G.R. No. L-21731 – 123 Phil. 400 – 16 SCRA 585 – Taxation Law – NIRC Rules of Procedure – Tax Collection – Period to Collect – No need for a final and executory assessment In January 1957, the Collector of Internal Revenue (CIR) made an assessment against Lim Tian […]
G.R. No. 175097 – 625 Phil. 530 – 611 SCRA 692 – Taxation Law – NIRC Rules of Procedure – Exception to the Rules of Procedure Regarding Protest and Appeal In April 2004, the Bureau of Internal Revenue (BIR) issued a preliminary assessment notice (PAN) to Allied Banking Corporation (ABC) […]
G.R. No. 76281 – 279 Phil. 132 – 202 SCRA 125 – Taxation Law – NIRC Rules of Procedure – Prescriptive Period – Tax Collection On December 16 and 17, 1974, the Commissioner of Internal Revenue (CIR) issued two assessment notices to Wyeth Suaco Laboratories, Inc. (Wyeth) asking the latter […]
G.R. No. L-46954 – 200 Phil. 672 – 115 SCRA 286 – Taxation Law – Tax Collection Suit – Jurisdiction – When Acquired In May 1962, Doroteo Yabes received an assessment notice from the Commissioner of Internal Revenue (CIR) demanding him to pay P15k in taxes. Doroteo filed a protest […]
G.R. No. 178087 – 634 Phil. 314 – Taxation Law – NIRC Procedure – Tax Assessment – Prescription – Waiver of the Statute of Limitations – Estoppel In April 1999, Kudos Metal Corporation (KMC) filed its annual income tax return (ITR). In September 1999, the Bureau of Internal Revenue (BIR) […]
G.R. No. 171251 – 683 Phil. 430 – Taxation Law – Failure of the CIR to Decide a Protest – Remedies of the Taxpayer In March 1998, the Commissioner of Internal Revenue (CIR) issued a formal assessment notice (FAN) to Lascona Land Co., Inc. (LLCI) demanding the latter to pay […]
G.R. No. 168498 – 524 Phil. 524 – 491 SCRA 213 – Taxation Law – Prescription – Appeal to the Court of Tax Appeals On 5 July 2001, the Commissioner of Internal Revenue (CIR) issued a final assessment notice (FAN) to the Rizal Commercial Banking Corporation (RCBC) demanding a total […]
G.R. No. 167146 – 536 Phil. 1131 – 506 SCRA 427 – Taxation Law – Tax Collection – Prescriptive Period – Reconsideration vs Reinvestigation In April 1991, Philippine Global Communication, Inc. (PGCI) filed its annual income tax return (ITR) for the taxable year 1990. A tax audit was subsequently conducted […]
G.R. No. 139736 – 510 Phil. 1 – 473 SCRA 205 – Taxation Law – Tax Collection – Prescriptive Period – Reconsideration vs Reinvestigation On October 20, 1989, the Bureau of Internal Revenue (BIR) issued a formal assessment notice (FAN) against the Bank of the Philippine Islands (BPI). The FAN […]
G.R. No. L-19495 – Taxation Law – Estate Taxes – Liability of Administrator In November 1966, the Supreme Court issued a decision declaring Lilia Gonzales to be liable for the entire tax deficiency due on an estate left by her father. Gonzales seeks reconsideration for her not to be adjudged […]
G.R. No. L-19495 – 124 Phil. 1395 – 18 SCRA 757 – Taxation Law – NIRC Rules of Procedure – Tax Assessment – Prescriptive Period – Defective Return In 1948, Matias Yusay died leaving behind two heirs, namely, Jose Yusay and Lilia Yusay Gonzales. Jose was appointed as administrator. He […]
G.R. No. 155541 – 465 Phil. 986 – 421 SCRA 275 – Taxation Law – NIRC Rules of Procedure – Assessment Must Be Sent To The Right Party (Taxpayer) Juliana Gabriel entered into a contract of agency with the Philippine Trust Company (PhilTrust) for the latter to manager her business […]
G.R. No. 162852 – 488 Phil. 218 – 447 SCRA 214 – Taxation Law – NIRC Rules – Assessment of Taxes – Formal Assessment Notice – Waiver of the Statute of Limitations In April 1995, the Philippine Journalists, Inc. (PJI) filed its income tax return for the year 1994. In […]