Case Digest (G.R. No. 249540) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Commissioner of Internal Revenue v. Arturo E. Villanueva, Jr. (G.R. No. 249540, February 28, 2024), the respondent, doing business as Producers Connection Logistics in Tondo, Manila, filed his 2006 Annual Income Tax Return and Quarterly VAT Returns on time. In June 2008 and May 2009, the Bureau of Internal Revenue (BIR) sent him letter notices and a Letter of Authority, followed by a First Call-up in May 2011 and a Final Notice Before Seizure dated June 6, 2011. The respondent sought clarification and reinvestigation through various letters, but his requests were denied in October 2012 and October 2014. On November 25, 2014, he filed a Petition for Review with the Court of Tax Appeals (CTA) First Division, which proceeded to trial after the BIR refused to dismiss the case despite the absence of a waiver of the statute of limitations. In its August 18, 2017 Decision, the CTA Division found that although the Preliminary Assessment Notice (PAN) and Final Assessment Notice (FAN) Case Digest (G.R. No. 249540) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Case Background
- Parties and Proceedings
- Commissioner of Internal Revenue (CIR) filed Petition for Review on Certiorari under Rule 45, challenging CTA EB Decision (Mar. 13, 2019) and Resolution (Sept. 16, 2019) which affirmed CTA Division Decision (Aug. 18, 2017) and Resolution (Jan. 10, 2018) in CTA Case No. 8935.
- CTA Division had canceled respondent’s 2006 deficiency income tax and VAT assessments on prescription grounds.
- Respondent’s Tax Filings and BIR Actions
- Arturo E. Villanueva Jr. filed 2006 Annual ITR and Quarterly VAT Returns on time.
- June 20, 2008: Letter Notice No. 029-WE-AI-00-00041.
- May 14 and June 15, 2009: Follow-up letter and Letter of Authority No. 2001-00012853.
- Dec. 28, 2010: PAN issued (Registry Receipt No. 921958).
- Jan. 24, 2011: FAN/FLD issued (Registry Receipt No. 903220).
- May–June 2011: 1st Call-up and Final Notice Before Seizure.
- Oct. 29, 2012: Collection Notice; respondent’s requests for revocation/reconsideration denied (Dec. 2013, Oct. 2014).
- Nov. 25, 2014: Petition filed with CTA Division; CTA Division trial ensued.
Issues:
- Whether the PAN and FAN were validly served upon respondent.
- Whether the BIR’s right to assess respondent for 2006 deficiency taxes has prescribed.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)