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Renato L. Liboro vs. CA

RENATO L. LIBORO, petitioner, vs. COURT OF APPEALS, COMMISSIONER OF INTERNAL REVENUE and COURT OF TAX APPEALS, respondents.

G.R. No. 101132 | 1993-01-29

D E C I S I O N

BELLOSILLO, J p:

These two cases have drawn the Office of the Solicitor General to take opposing sides of a common issue While it zealously defends respondents in G.R. No. 101132, it vigorously argues for petitioner in G.R. No. 105368. The petitions herein were consolidated because they involve common questions of law arising from a similar set of facts.

Statement of Facts

In G.R. No. 101132: Petitioner Renato L. Liboro is a practicing lawyer who on 15 April 1981 filed his income tax return for the year 1980. However, an examiner of the Bureau of Internal Revenue found his return deficient of P14,009.84. 1 On 30...