THE GREENBELT MADISON CONDOMINIUM ASSOCIATION, INC. v. COMMISSIONER OF INTERNAL REVENUE

,, REPUBLIC OF THE PHILIPPINES Court of Tax Appeals QUEZON CITY Special Second Division THE GREENBELT MADISON CTA CASE NO. 10789 CONDOMINIUM ASSOCIATION, INC., Members: Petitioner, RINGPIS-LIBAN, PJ, Chairperson, MODESTO-SAN PEDRO, and FERRER-FLORES, JJ -versus- Promulgated: r1-.' 2-}- /7?7 COMMISSIONER OF INTERNAL REVENUE, Respondent. X ------------------------------------------------------------------------------------ -- RESOLUTION MODESTO-SAN PEDRO, J.: For the Court's resolution is respondent's Motion for Partial Reconsideration (Re: Decision dated November 26, 2025), filed on December 26, 2025, with petitioner's Opposition (On the Motion for Partial Reconsideration dated 26 December 2025), filed via licensed courier on January 23, 2025, assailing this Court's Decision, dated November 26, 2025, which partially granted the instant Petition for Review by cancelling and setting aside the Warrant of Distraint and/or Levy ("WDL") against petitioner. The Motion lacks merit. Respondent claims that this Court failed to consider the fact that petitioner withdrew its Request for Reconsideration on December 23, 2021. In light of this withdrawal, no appeal was pending before respondent, so the assessment attained finality. The argument fails on multiple counts. First, it seems to ignore the fact this Court did, in fact, dismiss petitioner's prayer against the assessment itself. Our partial granting of the Petition covered only the WDL.

A RESOLliTION CTA CASE NO. 10789 Page 2 of2 Second, the argument overlooks and fails to discuss the fact that the WDL was issued on December 1, 2021. Petitioner withdrew its Request for Reconsideration afterwards, on December 23, 2021, and only because ofthe issuance ofthe WDL. As such, when the WDL was issued, there was still an administrative protest pending before respondent, rendering the WDL void. This was the basis of Our ruling. The WDL was prematurely issued on December 1, 2021, which, to reiterate, happened before the withdrawal of petitioner's Request for Reconsideration, on December 23, 2021, and even served as the reason for the latter. Respondent's argument thus completely fails to challenge Our ruling, and We consequently see no reason to depart from the assailed Decision. ACCORDINGLY, respondent's Motion for Partial Reconsideration (Re: Decision dated November 26, 2025), filed on December 26, 2025, is hereby DENIED for lack of merit. The Decision, dated November 26, 2025, is AFFIRMED. SO ORDERED. WE CONCUR: ~~~ )-=- MA. BELEN M. RINGPIS-LIBAN Presiding Justice C~G~~~~ Associate Justice