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Commissioner of Internal Revenue (CIR) vs. First Express Pawnshop Company, Inc.

COMMISSIONER OF INTERNAL REVENUE, Petitioner, versus FIRST EXPRESS PAWNSHOP COMPANY, INC., Respondent.

G.R. Nos. 172045-46 | 2009-06-16

D E C I S I O N
CARPIO, J.:

 

 
The Case
 
The Commissioner of Internal Revenue (petitioner) filed this Petition for Review[1] to reverse the Court of Tax Appeals' Decision[2] dated 24 March 2006 in the consolidated cases of C.T.A. EB Nos. 60 and 62. In the assailed decision, the Court of Tax Appeals (CTA) En Banc partially reconsidered the CTA First Division's Decision[3] dated 24 September 2004.
 
The Facts
 
On 28 December 2001, petitioner, through Acting Regional Director Ruperto P. Somera of Revenue Region 6 Manila, issued the following assessment notices against First Express Pawnshop Company, Inc....