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United Coconut Planters Bank vs. CIR

UNITED COCONUT PLANTERS BANK, PETITIONER, VS. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

CTA Case No. 7164 | 2006-07-26

D E C I S I O N
 
CASTAÑEDA, JR., J.:
 
This is a Petition for Review of the final Decision of the respondent Commissioner of the Bureau of Internal Revenue dated January 24, 2005, denying petitioner’s protest and thus affirming the deficiency assessments against petitioner for late payment of creditable withholding and documentary stamp taxes relative to the extrajudicial foreclosure sale of the real properties of Ever Gotesco Resources Holdings, Inc., in the aggregate amount of TEN MILLION SEVEN HUNDRED NINETY THOUSAND TWO HUNDRED SIXTY ONE AND 75/100 PESOS (P10,790,261.75). 

The facts as stipulated by the...