CTA Case No. 2240 (Resolution)
\ 'EPtfiLIC OJ' TBE PBlLIPPINEI COURT OF TAX APPE.lLI QUEZON CITY � RURAL BANK OF NlABINI C. T .. A. CASE hD . 2240 (BATANGAS) , INC. , Petitioner , - versus - COMMISSIONER OF INTEPJ\IAL REV~l\J'"l.JE , ~espondent . X- - - - - - - - - - - - - X RESOLUTION A uMotion to Dismissn the instant petition for review was fil ed by respondent on Ma y 7 , 1971 on the gTound that the appeal was prematurely file~ so th~t this Court lacks jurisdiction to entertain the same . An ~?cp-oosition. to th~ Motion to Dismissfl was filed by petitioner on Ma y :::n , 1971. Tie find merit in respondent ' s mction . Petitioner admits , in its petition fo.r revie1N and opposition to the motion to dismiss , that�its request for reconsideration of respondent ' s assess- ment dated July 15 , 1969 has not yet been finally decided . In other words , there is as yet no deci- sion on the disputed assessment wnich can be ele- vated to this Court for review . (Comm. of Int . Rev . vs . Villa , G. R. No. L-23988 , January 2 , 1968. ) The fa ct that there are other numerous assessments involving si~ilarly situated r ural banks , as .petitioner herein , whose requests for
REXLUTI 1~ - CTA CAS?. N) . 2240 -2- reconsideration have all been denied by respondent , does not furnish a sufficient legal -basis for the herein appeal. WHERE:FO E , finding respondent ' s motion to dismiss well taken , the petition for review has to be , as it is hereby , dismissed , without prejudice . ro ORD:2RED. Quezon City , May 28 , 1971 . ~~~ FUMAN M. ur tALI ' \ Presiding Judge Wl N L . AV '\1\ CEf: f' ~ rZ:__. ' k- ..JR~~~~AR'itZJ Associat e Judge Associate Judge
More in CTA Resolutions
- AYALA CORPORATION v. COMMISSIONER OF INTERNAL REVENUE(CTA Case No. EB 2417)
- NATIONAL TRANSMISSION CORPORATION v. CITY OF QUEZON, represented by its MAYOR, HON. FELICIANO BELMONTE JR. and VICTOR B. ENDRIGA, Ph. D., in his capacity as CITY TREASURER(CTA Case No. AC-165)
- CTA Case No. 4729 (Resolution)(CTA Case No. 4729)
- UPSI PROPERTY HOLDINGS, INC. v. COMMISSIONER OF INTERNAL REVENUE(CTA Case No. EB 1968)
- THE GREENBELT MADISON CONDOMINIUM ASSOCIATION, INC. v. COMMISSIONER OF INTERNAL REVENUE(CTA Case No. 10789)
- CTA Case No. 545 (Resolution)(CTA Case No. 545)
- CTA Case No. 3807 (Resolution)(CTA Case No. 3807)
- FORD GROUP PHILIPPINES, INC. v. COMMISSIONER OF INTERNAL REVENUE(CTA Case No. EB 3026)
Want an analysis of this document?
Ask ASG Legal AI to summarize it, compare it with other rulings, or explain how it applies to your situation — it researches from this same library.