Commissioner of Internal Revenue v. WPP Marketing Communications, Inc.

EN BANC[C.T.A. EB CASE NO. 2034. September 23, 2020.](C.T.A. Case No. 9778)COMMISSIONER OF INTERNAL REVENUE, petitioner, vs. WPP MARKETING COMMUNICATIONS, INC. (formerly known as J. Walter Thompson Company (Philippines), Inc.), respondent.DECISIONCASTAÑEDA, JR., J p:Before the Court En Banc is the Petition for Review filed by the Commissioner of Internal Revenue (CIR) under Rule 8, Section 3 (b) of the Revised Rules of the Court of Tax Appeals (RRCTA) in relation to Rule 43 of the Rules of Court which seeks to reverse the following:1. October 19, 2018 Resolution 1 of the CTA First Division, 2 the dispositive portion of which reads:"WHEREFORE, premises considered, petitioner's Partial Motion for Reconsideration (on the denial of the Motion to Suspend Collection of Taxes) is hereby GRANTED. Furthermore, based on the findings of this Court that the right of the respondent to collect the alleged deficiency taxes had already prescribed, the Petition for Review is hereby GRANTED. Accordingly, any collection of the alleged deficiency tax assessment for TY 1992 is DECLARED NULL AND VOID. CAIHTESO ORDERED."2. March 5, 2019 Resolution...