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Comm. Of Internal Rev. vs. American Airlines etal.

COMMISSIONER OF INTERNAL REVENUE, petitioner, vs. AMERICAN AIRLINES, INC. and COURT OF TAX APPEALS, respondents.

G.R. No. 67938 | 1989-12-19

D E C I S I O N


REGALADO, J.:

Petitioner Commissioner of Internal Revenue comes to this Court seeking the reversal of the decision of the Court of Tax Appeals (CTA, for short), promulgated on April 16, 1984 in CTA Case No. 3046. Respondent American Airlines Inc. was absolved in said decision of liability for the tax imposed under Section 24(b)(2) of the National Internal Revenue Code, as amended by Presidential Decree No. 69 promulgated on November 24, 1972. The provision reads:

"(2) Resident corporations. A corporation organized, authorized, or existing under the laws of any foreign country, engaged in trade and business within the...