cta_resolution CTA Case No. 30083008 1982-06-18

CTA Case No. 3008 (Resolution)

REPUBLIC OF THE PHILIPP~ COURT OFT~~ APPEALS nt �v.70N ("JTV PHILIPPINE AMERICAN INVESTMENT CORPORATION, Petitioner, - versus - C.T.A. CASE NO. 3008 COMMISSIONER OF INTERNAL REVENUE, Respondent. X- - - - ------X R ES 0 LUT I 0 N Acting on the "Manifestation And Motion" filed by counsel for petitioner on June 15, 1982, alleging: "1. That one of the items being contested in the above-entitled case is the assessment for 35% withholding tax against petitioner in the total amount of ~349,495.56 for the years 1973 and 1974; "2. That on June 9, 1982, on the strength of the letter-memorandum dated February 8, 1982 of the undersigned counsel toge.ther with documentary proofs in support of the arguments embodied in said memorandum, respondent Commissioner of Internal Revenue rendered a decision to the effect that the assessment for deficiency withholding taxes against petitioner for the years 1973 and 1974 in the sums of Pl89,766.12 and ~159,729.44, respectively, or a total of ~349,495.56, is withdrawn and cancelled. (Copy of said decision dated June 9, 1982 is here- to attached as Annex "A");

RESOLUTION - CTA CASE NO. 3008 - 2- "3. That another item in the ins- tant case (Par. IV of Petition for Review) involves petitioner's liability for deficiency income tax of ~2,754.25 and signified its willingness to pay said amount; 11 4. That, pursuant to the computa- tion of the Bureau of Internal Revenue, the total amount of ~3,845.12 was paid by petitioner representing the deficien- cy income tax of ~2,754.25, 5% surcharge and interest, as evidenced by Revenue Tax Receipt No. A-94833492 and Confirma- tion Receipt No. A-10009578 both dated June 9, 1982. (Xerox copies of said receipts are herewith enclosed as An- nex "B"); "5. That in its Resolution dated March 26, 1982, this Honorable Court ordered the withdrawal and cancellation of the assessment for personal holding company tax for 1974 in the sum of ~1,240,112.98 for reasons stated in the "Manifestation and Motion" filed by petitioner on December 14, 1981, which is one pf the items being contested in the instant case. AS PRAYED FOR, and without objection on the part of respondent, the said motion and manifestation is hereby GRANTED. Let the petition for review be considered withdrawn and this case deemed closed and ter- minated. SO ORDERED. City, June 18, 1982. Presidin Associate Judge CONSTANTE C. ROAQUIN is on leave.

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