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Philippine Guaranty Co. vs. CIR

THE PHILIPPINE GUARANTY CO., INC., petitioner, vs. THE COMMISSIONER OF INTERNAL REVENUE and THE COURT OF TAX APPEALS, ET AL., respondents.

G.R. No. L-22074 | 1965-09-06

R E S O L U T I O N* 


BENGZON, J. P., J.: 

The Philippine Guaranty Company, Inc. moves for the reconsideration of our decision, promulgated on April 30, 1965, holding it liable for the payment of income tax which it should have withheld and remitted to the Bureau of Internal Revenue in the total sum of P375,345.00. 

The grounds raised in the instant motion all spring from movant's view that the Court of Tax Appeals as well as this Court found it "innocent of the charges of violating, wilfully or negligently, sub-section (c) of Section 53 and Section 54 of the National Internal Revenue Code." Hence, it cannot subsequently be...