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Allied Banking Corporation Vs. Commissioner of Internal Revenue

ALLIED BANKING CORPORATION, Petitioner, versus COMMISSIONER OF INTERNAL REVENUE, Respondent

G.R. No. 175097 | 2010-02-05

D E C I S I O N


DEL CASTILLO, J.:

The key to effective communication is clarity.

The Commissioner of Internal Revenue (CIR) as well as his duly authorized representative must indicate clearly and unequivocally to the taxpayer whether an action constitutes a final determination on a disputed assessment.[1] Words must be carefully chosen in order to avoid any confusion that could adversely affect the rights and interest of the taxpayer.

Assailed in this Petition for Review on Certiorari[2] under Section 12 of Republic Act (RA) No. 9282,[3] in relation to Rule 45 of the Rules of Court, are the August 23, 2006 Decision[4] of the Court of...