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Philex Mining Corp Vs. CIR

PHILEX MINING CORPORATION, Petitioner, versus COMMISSIONER OF INTERNAL REVENUE, Respondent.

G.R. No. 148187 | 2008-04-16

DECISION


YNARES-SANTIAGO, J.:

This is a petition for review on certiorari of the June 30, 2000 Decision[1] of the Court of Appeals in CA-G.R. SP No. 49385, which affirmed the Decision[2] of the Court of Tax Appeals in C.T.A. Case No. 5200. Also assailed is the April 3, 2001 Resolution[3] denying the motion for reconsideration.

The facts of the case are as follows:

On April 16, 1971, petitioner Philex Mining Corporation (Philex Mining), entered into an agreement[4] with Baguio Gold Mining Company ("Baguio Gold") for the former to manage and operate the latter's mining claim, known as the Sto. Nino mine, located in Atok and Tublay,...