Angeles v. Court of Tax Appeals

SPECIAL SECOND DIVISION[CA-G.R. SP No. 76848. June 30, 2006.]SERGIO F. ANGELES, petitioner, vs. COURT OF TAX APPEALS and THE BUREAU OF INTERNAL REVENUE, respondents.D E C I S I O NJACINTO, J p:The herein Petition for Certiorari assails the Resolutions of the Court of Tax Appeals (CTA), which denied herein petitioner's Motion to Put Up Real Estate Mortgage in Lieu of Surety Bond and the subsequent Motion for Reconsideration, in CTA Case No. 5920 entitled "Sergio Angeles, Petitioner, versus, Bureau of Internal Revenue, Respondent." AcEIHCThe tax case stemmed from Assessment No. C-I-92-IT081-95 dated November 20, 1995 issued by the Bureau of Internal Revenue (BIR) to petitioner for the payment of Php24,320,920.48 in deficiency income tax, penalties and surcharges. (p. 50, Rollo) The assessment was based on the finding that in 1992 petitioner received as income from the exercise of his profession a 48,722-square meter piece of real property in Barangay Sta. Cruz, Antipolo City, but failed to pay the income taxes due thereon. (p. 43, Rollo)In connection with the said assessment, the BIR also issued...