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Commissioner Of Internal Revenue vs. Visayan Electric Company, Et Al.

COMMISSIONER OF INTERNAL REVENUE, petitioner, vs. VISAYAN ELECTRIC COMPANY and THE COURT OF TAX APPEALS, respondents.

G.R. No. L-22611 | 1968-05-27

D E C I S I O N 


SANCHEZ, J.: 

The problems cast in legal setting in this petition for review 1 of the judgment of the Court of Tax Appeals are: 
Is Visayan Electric Company liable for deficiency income tax on dividends from the stock investment of its employees' reserve fund for pensions? 

Is it also liable for 25% surcharge on alleged late payment of franchise tax? 

Respondent company is the holder of a legislative franchise, Act 3499 of the Philippine Legislature, to operate and maintain an electric light, heat, and power system in the City of Cebu, certain municipalities in the province of Cebu, and other...