4
CIR vs CA, CTA and ATENEO
FACTS:
Ateneos Institute of Philippine Culture (IPC)
- Non-stock, non-profit educational
institution with auxiliary units and
branches all over the Philippines
- Engaged in social science studies of
Philippine society and culture
- Accepts sponsorships for its research
activities from international organizations,
private foundations and government agencies
In 1983, IPC received from CIR a demand letter
assessing it for alleged deficiency contractors
tax and alleged deficiency income tax
- IPC denied said liabilities in a letterprotest and contested the validity of the
assessment with a memorandum sent to the
petitioner.
CIR rendered a letter-decision cancelling the
assessment for deficiency income tax but
modifying the assessment for deficiency
contractors tax by increasing the amount due.
- IPC then requested for a reconsideration or
reinvestigation of the modified assessment.
- But at the same time, filed a petition for
review of the said letter-decision in CTA.
- While the petition was pending, CIR issued a
final decision reducing the assessment for
deficiency contractors tax exclusive of
surcharge and interest.
Five years thereafter, CTA rendered its decision
setting aside CIRs decision, thereby cancelling
the deficiency contractors tax assessment.
CIR then filed with CA, petition for review
- CA affirmed the decision of CTA.