MARKET STRATEGIC FIRM, INC. v. COMMISSIONER OF INTERNAL REVENUE

REPUBLIC OF THE PHILIPPINES COURT OF TAX APPEALS QUEZON CITY SECOND DIVISION MARKET STRATEGIC FIRM, CTA CASE No. 9280 INC., Petitioner, Members: -versus- CASTANEDA, JR., Chairperson, MINDARO-GRULLA, and BACORRO-VILLENA, JJ. COMMISSIONER OF INTERNAL REVENUE, Respondent. x - - ------------ - --- -- --------- --- -- ------ - ------------------- ~ ----x RESOLUTION On May 10, 2019, this case was submitted for decision . On January 24, 2020, petitioner filed its Motion for Suspension of Proceedings due to its intended discussions and negotiations with the respondent for possible settlement of this case. However, absent actual compromise agreement entered into, the parties cannot practically keep hostage this Court's mandate, upon submission for decision, to promulgate its ruling, by mere allegation or manifestation of a possible settlement agreement. It must be realized that the instant case is for an assessment of alleged deficiency taxes and that no appeal from the decision of the respondent shall suspend the payment, levy or distraintl aside from exceptional cases provided for by law. 1 Republic Act 1125, Sect ion 11.

Ma r ket Strat egic Firm , Inc. vs. CI R Page 2 o f 2 CTA Case No. 9280 RESOLUTION It is only upon submission of a Judicial Compromise Agreement signed by authorized signatories with the approval of the National Evaluation Board and fu ll payment of the Judicial Compromise Amount2 that the Court sees no bar in approving the same. Absent this, t he promulgation of the decision must be in order. WHEREFORE, premises considered, the Motion for Suspension of Proceedings is hereby DENIED for lack of merit. S O ORD ERED. c. Q . a#~~ ~ J UANfiO C. CASTANE'DA, JR. Associate Justice ~ (J~ M~�J_.. ..Io _ b~ CI ELITO N. MINDARO- GRULLA Associate Justice ~ ~ - VILLENA 2 Section 6 of Revenue Regu lations (RR) No . 30-2002, as amended by RR No. 9-2013.