EIGHTEENTH DIVISION
[CA-G.R. SP No. 79758. April 16, 2007.]
A.L.L. PAWNSHOP, INC., petitioner, vs. COMMISSIONER OF INTERNAL REVENUE, respondents.
D E C I S I O N
DIZON, J p:
Before Us is a petition for review of the decision of the Court of Tax Appeals dated in September 03, 2003, CTA Case No. 64821.
The antecedent facts of the case are as follows:
Petitioner A.L.L. Pawnshop, Inc. is a corporation duly existing and organized under Philippine law. It is engaged in the pawnshop business.
On August 18, 2000, Regional Director of the Revenue No. 13, authorized officer Fidela Bardelas and Group Supervisor Jonathan Capanas of Revenue District No. 81 Cebu City-North, through Letter of Authority No. 1998-00022091, to examine petitioner's books of account and other accounting records for all internal revenue taxes for the calendar year 1999.
On September 06, 2001, respondent issued a Preliminary Assessment Notice for deficiency income tax of P35,227.82 and deficiency value-added tax (VAT) in the amount of P2,918,467.69 totaling P2,953,695.51 for taxable year 1999 but as to the deficiency tax, petitioner through a letter dated September 25,...
