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Comm of Internal Revenue vs Lingayen Gulf Electric 164 SCRA 27

THE COMMISSIONER OF INTERNAL REVENUE, petitioner, vs. LINGAYEN GULF ELECTRIC POWER CO., INC. and THE COURT OF TAX APPEALS, respondents.

G.R. No. L-23771 | 1988-08-04

D E C I S I O N


SARMIENTO, J.:

This is an appeal from the decision ** of the Court of Tax Appeals (C.T.A., for brevity) dated September 15, 1964 in C.T.A. Cases Nos. 581 and 1302, which were jointly heard upon agreement of the parties, absolving the respondent taxpayer from liability for the deficiency percentage, franchise, and fixed taxes and surcharge assessed against it in the sums of P19,293.41 and P3,616.86 for the years 1946 to 1954 and 1959 to 1961, respectively.

The respondent taxpayer, Lingayen Gulf Electric Power Co., Inc., operates an electric power plant serving the adjoining municipalities of Lingayen and Binmaley, both in the...