Back

National City Bank of New York vs. Posadas, Jr.

THE NATIONAL CITY BANK OF NEW YORK, plaintiff-appellant, vs. JUAN POSADAS, Jr., Collector of Internal Revenue of the Philippine Islands, defendant-appellant.

G.R. No. 41032 | 1934-09-21

D E C I S I O N


BUTTE, J:

Under section 1499 of the Administrative Code, the defendant Collector of Internal Revenue of the Philippine Islands assessed against the National City Bank of New York as capital and deposit taxes for the first half of the year 1931 the sum of P77,324.11. On October 23, 1931, the bank paid said taxes under protest. The grounds of the protest were stated as follows:

"1. That the National City Bank of New York is a national banking association duly organized under the United States National Banking Act and is an agency of the United States created under its laws to promote the fiscal policies of the United...