COMMISSIONER OF INTERNAL REVENUE v. EL PASO PHILIPPINES ENERGY COMPANY, INC.

Republic of the Philippines COURT OF TAX APPEALS Quezon City En Bane COMMISSIONER OF INTERNAL CTA EB No.1125 REVENUE, (CTA Case No. 7997) Petitioner, Present: DEL ROSARIO, PJ CASTANEDA, JR., BAUTISTA, - versus - UY, CASANOVA, FABON-VICTORINO, MINDARO-GRULLA, COTANGCO-MANALASTAS, and RINGPIS-LIBAN, 11. EL PASO PHILIPPINES ENERGY COMPANY, INC., Promulgated: Respondent. MAY 2 9 2015 x------------------------------------- -!!If=- ...3-.vr-r ~ !"::--:: .,._----- -x RESOLUTION CASANOVA, L.: Submitted for consideration are petitioner's "MOTION FOR RECONSIDERATION", filed on December 3, 2014, and respondent's "MOTION TO ADMIT ATTACHED COMMENT (on Petitioner's Motion for Reconsideration dated December 2, 2014)" filed on January 7, 2015. After petitioner's failure to file her comment on respondent's Motion to Admit Attached Comment (on Petitioner's Motion for Reconsideration dated December 2, 2014), as per Records Verification1 dated May 5, 2015, respondent's Motion is hereby GRANTED.~ 1 CTA En Bane Rollo, p. 223

RESOLUTION CTA EB No. 1125 (CTA Case No. 7997) Page 2 of3 Accordingly, the comment attached therewith is ADMITTED, forming part of the records of the case. Going now to the cynosure of this Resolution, after careful scrutiny by the Court En Bane of the arguments proffered by petitioner in her Motion for Reconsideration, We find that the issues, jurisprudence and discussions raised therein are mere rehash of the same issues, jurisprudence and discussions brought up in its Petition for Review 2 and Memorandum 3 which have already been analyzed, considered and passed upon in the promulgated Decision. The grounds raised by petitioner in her Motion did not raise anything new to merit any reconsideration thereof. Hence, We find no cogent justification to disturb the findings and conclusions reached by Court En Bane in the Decision dated November 11,2014. WHEREFORE, petitioner's Motion for Reconsideration is hereby DENIED for lack of merit. SO ORDERED. ~ CAESAR A. CASANOVA Associate Justice WE CONCUR: ROSARIO Presiding Justice ~~-~ C-~-..-F~l.. (UANITO C. CASTANEDA;JR. Associate Justice z Dated March 13, 2014, CTA En Bane Rollo, pp. 5-19 3 Dated July 28, 2014, CTA En Bane Rollo, pp. 139-150

RESOLUTION CTA EB No. 1125 (CTA Case No. 7997) Page 3 of3 (on leave) (On Leave) ERLINDA P. UY Associate Justice AMELIA R. COTANGCO-MANALASTAS Associate Justice ~N,M~~-C~ CIELITO N. MINDARO-GRULLA Associate Justice ():h.(.~~~ MA. BELEN M. RINGPIS-LIBAN Associate Justice