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Gen. Insurance and Surety Corp. vs. Commissioner of Internal Revenue

GENERAL INSURANCE AND SURETY CORPORATION, petitioner-appellant, vs. COMMISSIONER OF INTERNAL REVENUE, respondent-appellee.

G.R. No. L-29895 | 1973-04-30

D E C I S I O N

FERNANDO, J:

Petitioner would assail the decision of the Court of Tax Appeals sustaining the imposition of the 25% surcharge in the amount of P2,171.90 by respondent Commissioner of Internal Revenue for its failure to comply with the requirement as to the filing of the returns on the withholding taxes due on the salaries of its employees in accordance with the National Internal Revenue Code. 1 As a basis for its attack on the decision now sought to be reviewed, it would point to that portion of the statutory provision that would free a taxpayer from the imposition of the 25% surcharge on a showing of a "reasonable cause"...