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Commissioner of Internal Revenue vs Filinvest Development Corporation [DECISION]

COMMISSIONER OF INTERNAL REVENUE, Petitioner, vs. FILINVEST DEVELOPMENT CORPORATION, Respondent. COMMISSIONER OF INTERNAL REVENUE, Petitioner, vs. FILINVEST DEVELOPMENT CORPORATION, Respondent.

G.R. No. 163653 and G.R. No. 167689 | 2011-07-19

D E C I S I O N
 
PEREZ, J.:
 
Assailed in these twin petitions for review on certiorari filed pursuant to Rule 45 of the 1997 Rules of Civil Procedure are the decisions rendered by the Court of Appeals (CA) in the following cases:
 
(a) Decision dated 16 December 2003 of the then Special Fifth Division in CA-G.R. SP No. 72992; [1] and,
 
(b) Decision dated 26 January 2005 of the then Fourteenth Division in CA-G.R. SP No. 74510. [2]
 
The Facts

The owner of 80% of the outstanding shares of respondent Filinvest Alabang, Inc. (FAI), respondent Filinvest Development Corporation (FDC) is a holding company which also owned...