FORT BONIFACIO DEVELOPMENT CORPORATION, petitioner, vs. COMMISSIONER OF INTERNAL REVENUE, respondent.

FIRST DIVISION[CA-G.R. SP No. 79010. November 27, 2006.]FORT BONIFACIO DEVELOPMENT CORPORATION, petitioner, vs. COMMISSIONER OF INTERNAL REVENUE, respondent.D E C I S I O NREYES, R.T., P.J p:APPEALED in this petition for review under Rule 43 of the 1997 Rules of Civil Procedure is the Resolution 1 of the Court of Tax Appeals (CTA), which modified its earlier Decision 2 ordering petitioner to pay deficiency documentary stamp tax for the year 1995, by imposing twenty (20%) percent delinquency interest. Likewise sought to be reviewed is the action of the CTA entertaining respondent's partial motion for reconsideration of the Decision after petitioner has appealed it to this Court.The AntecedentsPetitioner Fort Bonifacio Development Corporation is a domestic corporation duly registered and existing under Philippine laws. It was originally incorporated as a wholly owned subsidiary of the Bases Conversion Development Authority (BCDA) for the purpose of developing portions of Fort Bonifacio in accordance with the Fort Bonifacio Master Development Plan.On February 8, 1995, the Republic of the Philippines (Republic) sold to petitioner portions of Fort Bonifacio for a...