[ G.R. No. 227049. September 16, 2020 ] 885 Phil. 288
SECOND DIVISION
[ G.R. No. 227049. September 16, 2020 ]
COMMISSIONER OF INTERNAL REVENUE, PETITIONER, VS. BANK OF THE PHILIPPINE ISLANDS, RESPONDENT. D E C I S I O N
INTING, J.:
This resolves the Petition for Review on Certiorari[1] under Rule 45 of the Rules of Court filed by the Commissioner of Internal Revenue (CIR) assailing the Court of Tax Appeals En Banc’s (CTA EB) Decision[2] dated March 17, 2016 and the Resolution[3] dated September 1, 2016 in CTA EB No. 1204 (CTA Case No. 8376). In the assailed issuances, the CTA EB affirmed the Decision[4] dated April 16, 2014 and the Resolution[5] dated July 23, 2014 of the CTA Third Division (CTA Division) in CTA Case No. 8376 that cancelled the Warrant of Distraint and/or Levy dated October 27, 2011 issued against Bank of the Philippine Islands (BPI).
The Antecedents
Through a letter dated May 6, 1991, the CIR sent Assessment Notices[6] to Citytrust Banking Corporation (Citytrust) in connection with its deficiency internal revenue taxes for the year 1986 in the aggregate amount of P20,865,320.29[7] computed as follows: