D E C I S I O N
CARPIO, J.:
The Case
This petition for review[1] seeks to set aside the 16 April 2002 Decision[2] of the Court of Appeals in CA-G.R. SP No. 66341 affirming the 8 August 2001 Decision[3] of the Court of Tax Appeals (CTA). The CTA ordered the Commissioner of Internal Revenue (petitioner)...
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