SECURITY BANK CORPORATION v. COMMISSIONER OF INTERNAL REVENUE

REPUBLIC OF THE PHILIPPINES COURT OF TAX APPEALS QUEZON CITY FIRST DIVISION SECURITY BANK CORPORATION, C.T.A. CASE No. 7505 (formerly Security Bank and Trust Company), Members: Petitioner, -versus- ACOSTA, Chairman BAUTISTA, and CASANOVA,JL COMMISSIONER OF INTERNAL Promulgated: REVENUE, JUN 2~08 :2"0~>.., X------------------------------------------R---e-s--p-o--n--d--e-n--t-.------------------------~~ ~ x RESOLUTION This Court notes petitioner's "Compliance" ftled on June 17, 2008 attaching thereto a certified true copy of the Termination Letter issued by the Bureau of Internal Revenue (BIR). The said Compliance is in accordance with the directive of this Court given during the hearing held on May 16, 2008, ordering petitioner to submit the original/certified true copy of the Termination Letter (Abatement Program Under RR15-2006). As stated in the said Termination Letter, by virtue of petitioner's availment of the benefits granted under the special provisions of Section 204 of the 1997 National Internal Revenue Code, as implemented by Revenue Regulations (RR) No. 15-2006 (Abatement Program ofthe BIR), and its consequent payment of the amount of P8,517,557.98 representing the one hundred percent (100%) of the basic tax assessed, its tax liability is already closed and terminated.

R ESOLUTION CTA CASE N O. 7505 Page2 This Court finds petitioner compliant with the requirements under RR No. 15-20061 as well as Revenue Memorandum Order No. 23-20062 which declare pending cases in courts withdrawn with the payment by the taxpayer of the am ount equal to one hundred percent (100%) of the basic tax being assessed. In a Resolution dated April 4, 2008, the instant case was deemed dismissed for failure to prosecute. This prompted petitioner to flle a Motion for Reconsideration on May 5, 2008 seeking the reinstatement of this case and asking that this case be archived, pending the issuance of the termination letter. With petitioner's submission o f the Termination Letter, the said Motion for Reconsideration has been rendered moot. ACCORDINGLY, the above-stated case 1s hereby considered CLOSED AND TERMINATED. Let a copy of this Resolution be furnished directly to the Commissioner of Internal Revenue for her information. SO ORDERED. L ". O~ ERNESTO D. ACOSTA Presiding Justice ~ CAESAR A. CASANOVA Associate Justice 1 Implementing a One-Time Administrative Abatement of all Penalties/Surchar;ges and Interest on Delinquent Accounts and Assessments (Preliminary or Final, Disputed or Not) as ofjune 30, 2006 2 Prescribing the Guidelines and Procedures on the One-Time Admimstrative Abatement ofall Penalties/Surchar;ges and Interest on Delinquent Au�ounts and Assessments (Preliminary or Final, Disputed or Not) as ofJune 30, 2006 as implemented lry Revenue Regulations No. 15-2006.