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Atlas Fertilizer Corporation vs. Commission of Internal Revenue, et al.

ATLAS FERTILIZER CORPORATION, petitioner, vs. COMMISSION OF INTERNAL REVENUE and COURT OF TAX APPEALS, respondents

G.R. No. L-26686 | 1980-10-30

D E C I S I O N


DE CASTRO, J.:

These two (2) cases are appeals by way of certiorari from the decision dated August 24, 1966 of the Court of Tax Appeals granting Atlas Fertilizer Corporation a tax credit in the sum of P81,899.00 which may be applied by said corporation in payment of its outstanding and/or future liability for internal revenue taxes.

For the material facts, We could very well quote from the decision of the Court of Tax Appeals, the following:

"Petitioner Atlas Fertilizer Corporation was formerly a department of Atlas Mining & Development Corporation. The latter was granted by the Secretary of Finance a certificate of...