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Collector Of Internal Revenue Vs. Jose Avelino, Et Al. 100 Phil 327

THE COLLECTOR OF INTERNAL REVENUE, petitioner, vs. JOSE AVELINO and COURT OF TAX APPEALS, respondents.

G.R. No. L-9202 | 1956-11-19

D E C I S I O N


BAUTISTA ANGELO, J.:

Jose Avelino filed his income tax returns for 1946 and 1948 on February 28, 1947 and April 20, 1949, respectively as required by law. A verification of said returns made by the examiners of the Collector of Internal Revenue revealed that there was due from the taxpayer on the basis of his increase in net worth every year, or under the inventory method, deficiency income taxes covering the years 1946 and 1948 in the amount of P83,212.63.

On May 24, 1954, or exactly five years and thirty-five days after the last of the two returns was filed, the Collector of Internal Revenue demanded from Jose Avelino...