This case has been cited 4 times or more.
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2015-12-07 |
VELASCO JR., J. |
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| In Commissioner of Internal Revenue v. FMF Development Corporation[7] the Court found the waiver in question defective because: (1) it was not proved that respondent therein was furnished a copy of the BIR-accepted waiver; (2) the waiver was signed by a revenue district officer instead of the Commissioner as mandated by the NIRC and RMO 20-90 considering that the case involved an amount of more than P1,000,000.00, and the period to assess was not yet about to prescribe; and (3) it did not contain the date of acceptance by the CIR. The Court explained that the date of acceptance by the CIR is a requisite necessary to determine whether the waiver was validly accepted before the expiration of the original period.[8] | |||||
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2014-11-12 |
LEONEN, J. |
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| This court said that the prescriptive period to make an assessment of internal revenue taxes is provided "primarily to safeguard the interests of taxpayers from unreasonable investigation."[71] | |||||
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2014-11-12 |
LEONEN, J. |
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| Rules derogating taxpayers' right against prolonged and unscrupulous investigations are strictly construed against the government.[74] | |||||
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2008-06-30 |
VELASCO JR., J. |
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| The motion for reconsideration was denied in an Order dated September 13, 2001.[5] MIAA appealed to the CA alleging grave abuse of discretion on the part of the RTC when it ordered MIAA to be re-impleaded as a party-defendant. The petition was docketed as CA-G.R. SP No. 67765. | |||||