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Commissioner Of Internal Revenue, Petitioner, Vs. Bank Of The Philippine Islands, As Liquidator Of Paramount Acceptance Corporation

COMMISSIONER OF INTERNAL REVENUE, petitioner, vs. BANK OF THE PHILIPPINE ISLANDS, as liquidator of PARAMOUNT ACCEPTANCE CORPORATION, respondent.

G.R. No. 135446. | 2003-09-23

D E C I S I O N

CORONA, J.:

Respondent Bank of the Philippine Islands (BPI) is the liquidator of Paramount Acceptance Corporation (PAC), a financing corporation which was dissolved on July 17, 1989 pursuant to the January 30, 1986 resolution of its Board of Directors and stockholders, shortening its corporate life to March 31, 1987.

After the dissolution of the PAC, respondent BPI learned from the newspapers that petitioner Commissioner of Internal Revenue (CIR) filed certain criminal cases against Horacio V. Poblador and Ramon A. Albert, former president and treasurer of PAC, respectively, for willful failure to pay the corporation's...