COMMISSIONER OF INTERNAL REVENUE v. RYAN NEIL ERASMO ALVEZ

REPUBLIC OF THE PHILIPPINES Court f~l Tax Appeals QUEZON CITY En Bane COMMISSIONER OF INTERNAL CTA EB NO. 2076 REVENUE Petitioner, (CTA OC No. 020) -versus- P re s e n t: DEL ROSARIO, P.J., CASTANEDA, JR., UY, RINGPIS-LIBAN, MANAHAN, BACORI~O-V ILLENA, and MODESTO-SAN PEDRO, JJ Prom uIgated: RYANNEIL ERASMOALVEZ, JUN 0 82021 ;;_ (JI'f2::2Z~t2:�'?x.""' . Respondent. X ------------------------------------------------------------------- RESOLUTIO N MODESTO-SAN PEDRO, J.: For reso lution is petitioner's Motion for Reconsideration fre: Decision dated 08 October 2020/ (hereinr~fier referred to as "Motion'') , posted on 29 October 2020 ,1 sans responde nt 's Comment/Oppositio n.2 In his Motion, petitioner reiterates his arg um ent that this Court has no jurisdiction to rev iew the va lidity of the assessment iss ued against respondent since it had already become fin a l, executory, and demandable. Moreover, he opines that even assuming that the Court does have jurisdiction to rul e on the assessment's validity, he stresses that the Court En Bane erred in ruling that the same is vo id for want of a uthority of the investigating revenue officers. I Petitioner filed his M otion w ithin 15 days rrom his rece ipt or th e assai led Decision on 14 October 2020. Hence, thi s Motion was ti mely filed. 2 Records Verification Report. �8 Records. p. 104 .

RESOLl;TION CTA EB NO. 2076 (CTA OC Cas~ No. 020) He emphasizes that the revenue officers, in this case, were duly authorized pursuant to a Memorandum of Assignment ("MOA") signed by Revenue District Officer Rogelio T. Balanga, who he alleges is one of the authorized signatories of an MOA. After a careful perusal of the foregoing arguments, the Court En Bane finds no merit in the Motion. The CIR's contentions are mere reiterations of his allegations in his Petition for Review, which have already been passed upon extensively by the Court En Bane in the assailed Decision As such, since petitioner failed to raise any new matter for the Court's consideration, the same finds no cogent reason to modify or reverse the assailed Decision. WHEREFORE, premises considered, petitioner's Motion for Reconsideration fre: Decision dated 08 October 2020/ is hereby denied for lack of merit. SO ORDERED. MARIA ~OW Justice A: WE CONCUR: ROMAN G. DEL ROSARIO Presiding Justice ~~ c .G.;T....-�1...t ~. (With due respect, l;oin J. Villena 's D. 0. in the Decision dated 8 Oct. 2020.) JUAN ITO C. CASTANEDA, JR. Associate Justice ERL~.UY Associate Justice

RESOLliTIO~ CTA EB NO. 2076 (C'TA OC Case No_ 020} Page 3 of3 ~- -41-. / ( MA. BELEN M. RINGPIS-LIBAN Associate Justice t:l ' ~7~ CATHERINE T. MANAHAN Associate Justice t- ~ (With due rr~rPfi JEANMA