Timeline (G.R. No. L-11305)

1. Corporate Structure
   The Manila Pencil Company, led by Dominador P. Canlas, is the successor in interest of the Philippine Consolidated Freight Lines, Inc.

2. Operational License
   From 1947 to 1951, the Philippine Consolidated Freight Lines, Inc. operated a bus and trucking service at Clark Field Air Base under a license from the Philippine Ryukyus Command (PHILRYCOM).

3. Income Tax Returns Filed
   The corporation filed income tax returns for its operations, with assessments for various fiscal years:

   • P4,285.74 for 1947
   • P21,733.66 for 1948
   • P7,933.57 for 1949
   • P3,332.00 for 1951

4. Partial Payment Made
   The company paid P4,000.00 as a partial payment of the income tax due for 1947.

5. Complaint Filed
   On March 24, 1954, the Solicitor General filed a complaint against the Manila Pencil Company and Dominador Canlas for unpaid income taxes (Civil Case No. 22366).

6. Tax Amounts Claimed
   The complaint claimed the following unpaid amounts:

   • Deficiency income tax for 1947: P1,084.97
   • Income tax for 1947: P285.74
   • Income tax for 1948: P21,733.65
   • Income tax for 1949: P7,933.57
   • Income tax for 1951: P3,332.00

7. Motion to Dismiss
   The defendants filed a motion to dismiss the complaint based on prescription and lack of jurisdiction.

8. Creation of Court of Tax Appeals
   Before the motion to dismiss was resolved, Republic Act No. 1125 was enacted, creating the Court of Tax Appeals.

9. Case Elevated
   The case was elevated to the Court of Tax Appeals for adjudication as per Section 22 of Republic Act No. 1125.

10. Den...continue reading