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CIR vs. CBC (Phil.) et al.

COMMISSIONER OF INTERNAL REVENUE, petitioner, vs. CONNEL BROS. COMPANY (PHIL.) and COURT OF TAX APPEALS, respondents.

G.R. Nos. L-27752-53 | 1971-08-30

D E C I S I O N


REYES, J.B.L., J:

Appeals from the joint decision and resolution of the Court of Tax Appeals in Cases Nos. 411 and 610, on the issue of the applicability of Section 51(d) and (e) of the National Internal Revenue Code, as amended, to delinquent taxes assessed prior to the effectivity of the amended provisions on 20 June 1959.

These cases commenced with the filing by Connel Bros. Company (Phil.), a domestic corporation, of petitions in the Court of Tax Appeals for review of the assessments made against it by the Commissioner of Internal Revenue for deficiency income taxes for 1955 in the sum of P28,065.00, said to be due...