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	GR No. 195615 2014-04-21	BANK OF COMMERCE v. RADIO PHILIPPINES NETWORK ABAD, J.
In fact, in Our November 13, 2013 Decision in G.R. No. 180529 entitled Commissioner of Internal Revenue v. Bank of Commerce,[34] where the same PSA between TRB and Bancom had been scrutinized to resolve the issue of whether Bancom can be held liable for the liabilities of TRB, sustaining the findings of the BIR and Court of Tax Appeals (CTA), this Court categorically ruled in the negative, viz: As the CTA En Banc stated in its Amended Decision, the issue boils down to whether or not BOC is liable for the deficiency DST of TRB for taxable year 1999.