G.R. No. 184068 - Guy vs. Guy

Pacific Hub Corporation filed withholding tax on compensation, expanded withholding tax, and value-added tax returns for 2005 and 2006.
The company declared a total of PHP 30,985,617.52 but remitted only PHP 15,505,386.41, leaving a difference of PHP 15,480,231.11 unpaid.

In 2008, Pacific Hub sent a letter to the Bureau of Internal Revenue (BIR) expressing willingness to pay the outstanding taxes but requested penalty, surcharge, and interest abatement due to financial losses.
In 2010, it filed an Application for Abatement or Cancellation of Tax, Penalties and/or Interest and paid the basic deficiency tax of PHP 15,480,231.11.

The Commissioner of Internal Revenue (CIR) issued a Notice of Denial dated January 10, 2014, rejecting Pacific Hub's application for abatement.
Subsequently, a Warrant of Distraint and/or Levy dated September 12, 2014 was issued to enforce collection of PHP 13,792,867.56 corresponding to increments on deficiency withholding tax.

Pacific Hub filed a Petition for Review with the Court of Tax Appeals (CTA) to annul the Notice of Denial and Warrant, citing irregular issuance and violation of due process.
CIR challenged the CTA’s jurisdiction and defended the denial as discretionary and proper.
The CTA Third Division annulled the Notice of Denial and Warrant, holding the CTA had "other matters" jurisdiction and declaring the Warrant void for absence of prior assessment and the Notice void for lack of reasons.
The CIR moved for reconsideration which was denied; then appealed to the CTA en banc which affirmed the Third Division Decision.
The CTA en banc upheld that the denial lacked reasons required under Revenue Regulations No. 13-2001 and that the issuance of Warrant without a prior assessment violated due process.

CIR argued the CTA lacked jurisdiction and that the denial and Warrant were valid.
The Supreme Court denied the Petition, affirming the CTA’s ruling.

Whether the Court of Tax Appeals had jurisdiction to review the issuance of the Notice of Denial of Pacific Hub's application for abatement.
Whether the Notice of Denial issued by the Commissioner of Internal Revenue complied with legal and regulatory requirements, specifically Revenue Regulations No. 13-2001.
Whether the Warrant of Distraint and/or Levy was validly issued without a prior assessment against Pacific Hub.