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 […]
case digest
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 […]
G.R. No. L-11527 – 104 Phil. 819 – Taxation Law – NIRC Rules of Procedure – Estoppel – Waiver of the Statute of Limitations Due to the chaos caused by World War II, Congress extended the filing of income tax returns for the year 1941. The extension was up to […]