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Commissioner Of Internal Revenue Vs. Court Of Appeals, Et Al.

COMMISSIONER OF INTERNAL REVENUE, petitioner, vs. COURT OF APPEALS and ATLAS CONSOLIDATED MINING AND DEVELOPMENT CORPORATION, respondents. Redentor O. Guyala for private respondent. M.L. Gadioma Law Office collaborating counsel for private respondent.

G.R. No. 86785 | 1991-11-21

D E C I S I O N


REGALADO, J.:

With commendable zeal, petitioner, through the Solicitor General, assails the decision in CA-G.R. No. 15429 of the Court of Appeals, 1 promulgated on January 20, 1989, affirming the decision of the Court of Tax Appeals in C.T.A. Case No. 2778 which granted a tax credit of P170,476.64 representing ad valorem taxes paid by private respondent for the period from the first quarter of 1974 to the third quarter of 1975.

The findings of fact of the Court of Tax Appeals, which were adopted by the Court of Appeals, are not disputed by petitioner and are hereunder
reproduced:

"1. Petitioner is a mining corporation...