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Commissioner of Internal Revenue Vs. Fort Bonifacio Development Corporation

COMMISSIONER OF INTERNAL REVENUE, Petitioner, versus FORT BONIFACIO DEVELOPMENT CORPORATION, Respondent

G.R. No. 167606 | 2010-08-11

D E C I S I O N


MENDOZA, J.:

At bar is a petition for review under Rule 45 of the Rules of Court, filed by the Commissioner of Internal Revenue (CIR) against Fort Bonifacio Development Corporation (FBDC), challenging the Resolutions of the Court of Appeals (CA) dated: (1) January 27, 2003,[1] denying the prayer of petitioner CIR and the Revenue District Officer, Revenue District No. 44, Taguig and Pateros, Bureau of Internal Revenue (BIR), to admit the Amended Petition for Review; and (2) March 18, 2005,[2] denying their motion for the reconsideration thereof.

In its decision[3] dated December 7, 2001, the Court of Tax Appeals (CTA)...