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THIRD DIVISION
G.R. No. 1798
!ACTS AS TO PETITIONER
Revenue [CIR] is the duly authorized government official empowered, among others, to
refund erroneously collected taxes under the 199 !"IRC#$ %n &e'ruary (), (**), CIR
received from +,- a claim for refund representing the total amount of 1*. %C/ paid to
+-0/ from 1anuary to 0ecem'er (**($ 0ue to the Commissioner2s inaction on its claim for
refund, +,- appealed 'efore the C/, on ,pril ((, (**)$
!ACTS AS TO RESPONDENT
+,- availed [of] the communication services of !+-0/#$ &or the period 1anuary 1, (**( to
0ecem'er 31, (**(, +,- allegedly paid +-0/ the 1*. %C/ in on its overseas telephone
calls$ &or the %C/ it paid, it file claim for refund with the CIR which failed to ta4e action
hence the claim was elevated to the C/,$ Respondent +,- argued that since it incurred
negative taxa'le income
5
for fiscal years (**( and (**3 and opted for zero 'asic corporate
income tax, which was lower than the (. franchise tax, respondent +,- had complied with
the 6in lieu of all other taxes6 clause !+$0$# "o$ 179*$