PEOPLE OF THE PHILIPPINES v. FJORD INTERNATIONAL CORPORATION/NICHOLSON C. SANTOS (President) and JOSEPHINE CHEN (Treasurer) Unit 1205 World Trade Center Exchange Building 215 Juan Luna Street, Brgy. 287, Zone 27, Binondo, Manila (AT-Large)

REPUBLIC OF THE PHILIPPINES COURT OF TAX APPEALS QUEZON CITY FIRST DIVISION PEOPLE OF THE PHILIPPINES, CTA Crim. Case No. 0 -812 Plaintiff, (NPS Docket No. XVI-INV- 19D-00143) -versus- For: Violation of Section 255 in relation to Sections 253 and 256 of FJORD INTERNATIONAL the NIRC of 1997, as amended. CORPORATION/NICHOLSON C. SANTOS (President) and Members: JOSEPHINE CHEN (Treasurer), DEL ROSARIO ,P.J.,Chairperson, A ccused. a nd MANAHAN, JJ. Promulgated: s 9) 2:;.- ){- - - - - - - - - - - - - - - - - - - - - - - - - - -~ - - - - - ~ - - - - - - - ){ RESOLUTION In a Resolution dated May 27, 2020, plaintiff was given five (5) days from r eceipt of notice to submit additional proof/ documentary evidence to establish the roles or designation of accused Nicholson C. Santos and Josephine Chen in the subject corporation at the time the crime was allegedly committed in 2018. Records sh ow that plaintiff r eceived the Court's Resolution dated May 27, 2020 on July 1, 2020, hence it had until July 6, 2020 to comply with the directive embodied in said Resolution.

RESOLUTION CTA CRIM. CASE No. 0-812 Page 2 of2 Records further show that as of July 28, 2020, plaintiff failed to comply with the Resolution of the Court. 1 WHEREFORE, considering plaintiffs failure to comply with this Court's Resolution dated May 27, 2020, which will establish the role or designation of accused Nicholson C. Santos and Josephine Chen in the subject corporation at the time the crime was committed under Section 255, in relation to Section 253 (d) and Section 256 of the 1997 National lntemal Revenue Code (NIRC), as amended, Criminal Case No. 0-812 is hereby DISMISSED for lack of probable cause. SO ORDERED. Presiding Justice c~~T. ' /7'~........ MAN. Associate Justice 1 Records Verification Notice dated July 28, 2020.