THIRD DIVISION
D E C I S I O N
PERALTA, J.:
Before the Court is a petition for review on certiorari under Rule 45 of the Rules of Court seeking to reverse and set aside the Decision1 and Resolution2 of the Court of Tax Appeals (CTA) En Banc, dated December 17, 2010 and May 27, 2011, respectively, in CTA EB No. 548. The assailed Decision affirmed the July 3, 2009 Decision3and September 30, 2009 Resolution4 of the CTA Second Division in CTA AC No. 51, while the questioned Resolution denied herein petitioners' Motion for Reconsideration.
The factual and procedural antecedents of the case are as follows:
On the strength of the...
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