Lapanday Foods Corp. v. Commissioner of Internal Revenue

EN BANC[C.T.A. EB CASE NO. 2032. July 22, 2020.](C.T.A. Case No. 9885)LAPANDAY FOODS CORPORATION, petitioner, vs. COMMISSIONER OF INTERNAL REVENUE, respondent.DECISIONBACORRO-VILLENA, J p:At bar is a Petition for Review 1 filed by petitioner Lapanday Foods Corporation (petitioner/LFC) seeking to nullify the Resolutions dated 10 September 2018 2 and 21 February 2019, 3 respectively, of the Court's Third Division in CTA Case No. 9885, entitled Lapanday Foods Corporation v. Commissioner of Internal Revenue. The dispositive portion of the assailed 10 September 2018 Resolution reads: xxx xxx xxxWHEREFORE, the Petition for Review filed by petitioner Lapanday Foods Corporation is hereby DISMISSED, for lack of jurisdiction.SO ORDERED.xxx xxx xxxThe Special Third Division 4 denied petitioner's Motion for Reconsideration (MR) of the above Resolution on 21 February 2019, viz.:xxx xxx xxxWHEREFORE, the Motion for Reconsideration (of the Resolution dated 10 September 2018) dated September 28, 2018 filed by petitioner is hereby DENIED, for lack of merit.With the affirmation of the dismissal of the Petition for Review, the (1) Urgent Motion for Additional Time To File Answer dated December 3,...