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TMX Sales filed its quarterly income tax return for the first quarter of 1981, paying income tax. It later suffered losses in 1981 and filed an annual return showing a net loss. It filed a claim for a refund of the taxes paid in the first quarter, which was not acted on. It then filed a petition with the court. The CIR argued the claim was barred by the two year statute of limitations. The CTA ruled in favor of TMX Sales, finding the two year period begins from the date of the final payment or last installment per previous cases. The SC agreed and held that considering the various tax code provisions together, the two year period begins from the date of filing the annual adjustment return when any overpayment
TMX Sales filed its quarterly income tax return for the first quarter of 1981, paying income tax. It later suffered losses in 1981 and filed an annual return showing a net loss. It filed a c…