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	GR No. 167679 2015-07-22	ING BANK N.V. v. CIR LEONEN, J.
Moreover, in the fairly recent case of LG Electronics Philippines, Inc. v. Commissioner of Internal Revenue,[71] we confirmed that only cases that involve final and executory judgments are excluded from the tax amnesty program as explicitly provided under Section 8 of Republic Act No. 9480.[72]