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CIR v. PRIMETOWN PROPERTY GROUP

This case has been cited 1 times or more.

2014-06-30
PERALTA, J.
And Sixth, granting for the sake of argument that this Court should take into account 2004 as a leap year and that the one-year period to revive the case should be reckoned from the date of receipt of the order of provisional dismissal by Uy, We still hold that the motion to revive the criminal cases against Co was timely filed. A year is equivalent to 365 days regardless of whether it is a regular year or a leap year.[39] Equally so, under the Administrative Code of 1987, a year is composed of 12 calendar months. The number of days is irrelevant. This was our ruling in Commissioner of Internal Revenue v. Primetown Property Group, Inc.,[40] which was subsequently reiterated in Commissioner of Internal Revenue v. Aichi Forging Company of Asia, Inc.,[41] thus: x x x [In] 1987, EO 292 or the Administrative Code of 1987 was enacted. Section 31, Chapter VIII, Book I thereof provides: