COMMISSIONER OF INTERNAL REVENUE v. ESTATE OF MA. ROSARIO S. CABRERA (also known as Rosario S. Cabrera and Maria Rosario S. Cabrera), REPRESENTED BY CO-EXECUTORS EDUARDO JULIAN C. PASCUAL AND ANDRES ELIGIO C. PASCUAL

REPUBLIC OF THE PHILIPPINES COURT OF TAX APPEALS QUEZON CITY ENBANC COMMISSIONER OF INTERNAL CTA EB NO. 1503 REVENUE, (CTA Case No. 8785) Petitioner, Present: DEL ROSARIO, P.J., CASTANEDA, JR., -versus- BAUTISTA, UY, CASANOVA, FABON-VICTORINO, MINDARO-GRULLA, ESTATE OF MA. ROSARIO S. RINGPIS-LIBAN, and CABRERA (also known as Rosario S. MANAHAN, JJ. Cabrera and Maria Rosario S. Cabrera), REPRESENTED BY CO- EXECUTORS EDUARDO JULIAN C. PASCUAL and ANDRES ELIGIO Promulgated: C. PASCUAL, Respondent. NOV 2 9 2017 o2: ..<!/)-/". -~ X- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -- - - - - - - - - - - -X RESOLUTION RINGPIS-LIBAN, J.: This resolves Petitioner's "Motion for Reconsideration" ftled on August 23, 20171 seeking to set aside the Decision2 promulgated on July 25, 2017 (Assailed Decision). On September 08, 2017, this Court issued a Resolution3 ordering Respondent to comment on the MR within ten (1 0) days from notice. In /Y 1 Rollo, pp. 72-77. 2 Id. at pp. 54-65. 3 Id. at p. 82.

RESOLUTION CTA EB NO. 1503 (CTA Case No. 8785) response thereto, Respondent ftled its "Comment/Opposition (Re: Motion for Reconsideration dated 22 August 2017)" on October 05, 2017.4 The dispositive portion of the Assailed Decision reads as follows: WHEREFORE, premises considered, the Petition for Review is hereby DENIED for lack of merit. The Decision dated May 04,2016 and the Resolution dated July 29,2016 of the Second Division in CTA Case No. 8785 are hereby AFFIRMED.5 After a careful consideration and evaluation of the parties' respective arguments, the Court finds that the arguments raised in Petitioner's Motion for Reconsideration are mere rehash of Petitioner's arguments in his Petition for Review, and have already been amply discussed, passed upon and considered by this Court in the Assailed Decision sought to be reconsidered. Petitioner's arguments constitute neither compelling nor cogent reason to modify, much less reverse the Assailed Decision. WHEREFORE, premises considered, Petitioner's "Motion for Reconsideration" is DENIED for lack of merit. SO ORDERED. Qb..c. ~ J " MA. BELEN M. RINGPIS-LIBAN Associate Justice WE CONCUR: Presiding Justice 9.e-.~ ~ LOVEiR. BAUTISTA JUANffo c. CAST.ANEISA, JR. Associate Justice Associate Justice 4 Id. at pp. 84-101. 5 Id. at p. 64.

RESOLUTION CTA EB NO. 1503 (CTA Case No. 8785) E~AP.UY CAESAR A. CASANOVA Associate Justice Associate Justice ~ ~tM~-C~ CIELITO N. MINDARO-GRULLA Associate Justice � ~--7�/Uif?YYI~ CATHERINE T. MANAHAN Associate Justice