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Kasamahan Realty Development vs. CIR

SECOND DIVISION [C.T.A. CASE NO. 6204. February 16, 2005.] KASAMAHAN REALTY DEVELOPMENT CORPORATION (now known as STAG TRADING CORPORATION), petitioner, vs. COMMISSIONER OF INTERNAL REVENUE, respondent. D E C I S I O N

CTA Case No. 6204 | 2005-02-16

Before Us is the Petition for Review filed by petitioner on November 24, 2000 involving deficiency income tax assessment in the aggregate amount of P44,578,524.36 for the taxable year 1994.   

Borne from the records and Joint Stipulation of Facts by the parties, 1 the following are the uncontested facts:
On April 17, 1995, petitioner filed its 1994 Corporate Annual Income Tax Return and paid the amount of P1,403,574.00 as its tax due. The amount paid was computed as follows:

Gross Income:

Phelps Dodge Phils., Inc.                 P37,513.01
Atlas Consolidated Mining Corp. 738,000.00
...