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Philippine National Oil Company (PNOC) vs. Court of Appeals 457 SCRA 32

PHILIPPINE NATIONAL OIL COMPANY, Petitioner, versus THE HON. COURT OF APPEALS, THE COMMISSIONER OF INTERNAL REVENUE and TIRSO SAVELLANO, Respondents.

G.R. No. 109976 | 2005-04-26

D E C I S I O N
 
 
CHICO-NAZARIO, J.:
 
This is a consolidation of two Petitions for Review on Certiorari filed by the Philippine National Oil Company (PNOC)[1] and the Philippine National Bank (PNB),[2] assailing the decisions of the Court of Appeals in CA-G.R. SP No. 29583[3] and CA-G.R. SP No. 29526,[4] respectively, which both affirmed the decision of the Court of Tax Appeals (CTA) in CTA Case No. 4249.[5]
 
The Petitions before this Court originated from a sworn statement submitted by private respondent Tirso B. Savellano (Savellano) to the Bureau of Internal Revenue (BIR) on 24 June 1986. Through his sworn statement,...