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Republic Bank Vs. Court Of Tax Appeals, Et Al. 213 SCRA 266

REPUBLIC BANK, petitioner, vs. COURT OF TAX APPEALS AND THE COMMISSIONER OF INTERNAL REVENUE, respondents.

G.R. Nos. 62554-55 | 1992-09-02

D E C I S I O N


NOCON, J.:

Petitioner Republic Bank appeals the decision of public respondent Court of Tax Appeals dated September 30, 1982 dismissing its Petition for Review, thereby affirming public respondent Commissioner of Internal Revenue's assessment for petitioner's reserve deficiency taxes inclusive of 25% surcharge for the taxable years 1969 and 1970 in the amounts of P1,325,768.82 and P1,953,132.67, respectively.

The antecedent facts as briefly summarized by the Solicitor General are as follows:

"On 14 September 1971, respondent Commissioner assessed petitioner the amount of P1,060,615.06, plus 25% surcharge in the amount of...