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HEDCOR, INC., PETITIONER, VS. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

HEDCOR, INC., PETITIONER, VS. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

G.R. No. 207575 | 2015-07-15

FIRST DIVISION
 
R E S O L U T I O N
 
SERENO, C.J.:
 
This is a Petition for Review filed by Hedcor, Inc. (petitioner) assailing the Court of Tax Appeals (CTA) en banc Decision[1] dated 1 October 2012 and Resolution[2] dated 28 May 2013 in C.T.A. EB No. 785.  The CTA en banc affirmed the CTA Second Division Resolutions dated 19 January 2011[3] and 12 May 2011[4] of the in C.T.A. Case No. 8129.  The latter granted the Motion to Dismiss filed by the Commissioner of Internal Revenue (CIR) and dismissed the Petition for being filed out of time.
 
The Facts
 
The facts, as culled from the...