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Commissioner of Internal Revenue Vs. Bank of Commerce

COMMISSIONER OF INTERNAL REVENUE, Petitioner, vs. BANK OF COMMERCE, Respondent.

G.R. No. 180529 | 2013-11-13

FIRST DIVISION

DECISION

LEONARDO-DE CASTRO, J.:

This is a Petition (or Review on Certiorari 1 filed by the Commissioner of Internal Revenue (CIR) wherein the September 17, 2007 Amended Decision2 and November 15, 2007 Resolution3 of the Court of Tax Appeals En Bane (CTA) in C.T.A. EB No. 259, are sought to be nullified and set aside. 4

The facts of the case, as stipulated by the parties are as follows:

1. [Bank of Commerce (BOC)] is a banking corporation duly organized and existing under and by virtue of the laws of the Republic of the Philippines, with principal office address at Iih Floor, Bankers' Centre Building, 6764 Ayala Avenue, Makati...