SIXTEENTH DIVISION
[CA-G.R. SP No. 84485. November 21, 2005.]
FIRST KIMEX TRADE, INC. petitioner, vs. THE COMMISSIONER OF INTERNAL REVENUE, respondent.
D E C I S I O N
SABIO, J. L., JR., J p:
Sought to be annulled and set aside in this petition for review under Rule 43 of the 1997 Rules of Civil Procedure are the December 23, 2003 Decision 1 and May 11, 2004 Resolution 2 of the Court of Tax Appeals (CTA) in CTA Case No. 6148.
The material antecedents:
Pursuant to a Letter of Authority dated August 11, 1995 issued by Revenue District Officer (RDO) Mamerto Silangcruz, Jr. of Revenue District No. 50, South Makati, the examiners of the Bureau of Internal Revenue (BIR) conducted an examination of the books of accounts and other accounting records of petitioner First Kimex Trade, Inc. (FKTI) for income and other taxes covering the year 1994.
Upon conclusion of the examination, petitioner FKTI was found to have corporate income tax deficiency of P9,985,149.06 and value-added. tax deficiency of P3,084,959.49 for the calendar year 1994. As a result thereof, petitioner was...
