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CIR vs. Enron Subic Power Corporation

COMMISSIONER OF INTERNAL REVENUE, Petitioner, versus ENRON SUBIC POWER CORPORATION, Respondent.

G.R. No. 166387 | 2009-01-19

R E S O L U T I O N

CORONA, J.:

In this petition for review on certiorari under Rule 45 of the Rules of Court, petitioner Commissioner of Internal Revenue (CIR) assails the November 24, 2004 decision[1] of the Court of Appeals (CA) annulling the formal assessment notice issued by the CIR against respondent Enron Subic Power Corporation (Enron) for failure to state the legal and factual bases for such assessment. 

Enron, a domestic corporation registered with the Subic Bay Metropolitan Authority as a freeport enterprise,[2] filed its annual income tax return for the year 1996 on April 12, 1997. It indicated a net loss of P7,684,948....