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Commissioner of Internal Revenue. vs. British Overseas Airways Corporation (BOAC)

COMMISSIONER OF INTERNAL REVENUE, petitioner, vs. BRITISH OVERSEAS AIRWAYS CORPORATION and COURT OF TAX APPEALS, respondents.

G.R. Nos. L-65773-74 | 1987-04-30

D E C I S I O N

MELENCIO-HERRERA, J.:
 
Petitioner Commissioner of Internal Revenue (CIR) seeks a review on Certiorari of the joint Decision of the Court of Tax Appeals (CTA) in CTA Cases Nos. 2373 and 2561, dated 26 January 1983, which set aside petitioner's assessment of deficiency income taxes against respondent British Overseas Airways Corporation (BOAC) for the fiscal years 1959 to 1967, 1968-69 to 1970-71, respectively, as well as its Resolution of 18 November, 1983 denying reconsideration.
 
 
 
 
BOAC is a 100% British Government-owned corporation organized and existing under the laws of the United Kingdom. It...