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Commissioner of Internal Revenue (CIR) vs. Trustworthy Pawnshop, Inc..

COMMISSIONER OF INTERNAL REVENUE, Petitioner, versus TRUSTWORTHY PAWNSHOP, INC., Respondent.

G.R. No. 149834 | 2006-05-02

SECOND DIVISION
 
D E C I S I O N
 
 
SANDOVAL-GUTIERREZ, J.
 
At bar is a Petition for Review on Certiorari under Rule 45 of the 1997 Rules of Civil Procedure, as amended, assailing the Decision [1] dated August 29, 2001 of the Court of Appeals in CA-G.R. SP No. 59250. 
 
The undisputed facts are: 
 
Trustworthy Pawnshop, Inc. (respondent Pawnshop) is a domestic corporation engaged in the pawnshop business. 
 
On March 11, 1991, the Commissioner of Internal Revenue (CIR) issued Revenue Memorandum Order (RMO) No. 15-91, classifying the pawnshop business as "akin to the lending investor's...