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Commissioner of Internal Revenue vs. Manila Bankers' Life Insurance Corporation

COMMISSIONER OF INTERNAL REVENUE, Petitioner, vs. MANILA BANKERS' LIFE INSURANCE CORPORATION, Respondent.

G.R. No. 169103 | 2011-03-16




FIRST DIVISION

D E C I S I O N


LEONARDO-DE CASTRO, J.:


This is a Petition for Review on Certiorari1 filed by the Commissioner of Internal Revenue (CIR) of the April 29, 2005 Decision2 and July 27, 2005 Resolution3 of the Court of Appeals in CA-G.R. SP No. 70600, which upheld the April 4, 2002 Decision4 of the Court of Tax Appeals (CTA) in CTA Case No. 6189.


The facts as found by the CTA and Court of Appeals are undisputed.


Respondent Manila Bankers' Life Insurance Corporation is a duly organized domestic corporation primarily engaged in the life insurance business.5


On May 28, 1999, petitioner Commissioner of Internal Revenue issued Letter of...