CTA Case No. 1267 (Decision)

THE UNITED ST TES LIFE INSUR NCE COMP NY IN THE CITY OF HE\v YORK , Petitioner, - versus - C. T�� CASE NO . 1267 COMHISSIONER OFINTERNAL REVENUE , Respondent . X- - - - - - - - - - - - - - - X DECI S I 0 N This is an appeal by the petitioner from the res - pondent ' s demand for the payment of i>300o00 as "compro- mise penalty" for alleged violation of Section 4- of the Bookkeeping Regulations (Revenue Regulations No o V- 1 , as amended) in relation to Section 352 of the National Internal Revenue Code o Petitioner is a corporation organized and exist- ing under the laws of the State of New York and licensed to do life insurance business in the Philippines . On February 20, 1958 , petitioner wrote a letter to the Col- lector (now Commissioner) of Internal Revenue certify- ing the number of loose- leaf sheets used in its cash receipts and general ledger for the year l957o As the number of loose- leaf sheets used did not tally with that stated in the certification and that petitioner failed to have the certification under oath, respondent sug- gested that petitioner pay a "compromise penalty" in the amount of P6oo . oo in extra- judicial settlement of its penal liability under Section 352 of the Revenue Code . The discrepancy was explained by peti~ioner and res - pendent agreed to reduce the alleged penalty to P300o00 . 40

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