May 4, 1962
REVENUE MEMORANDUM CIRCULAR NO. 16-62
| SUBJECT | : | Publishing the Decision of the Supreme Court in the Cases Entitled Collector of Internal Revenue vs. Antonio Prieto, et al., G.R. No. L-11976 and Commissioner of Internal Revenue vs. Asturias Sugar Central, Inc., G.R. No. L-15013 |
| TO | : | All Internal Revenue Officers and Others Concerned |
For the information and guidance of all concerned, pertinent portions of the decisions in the above-entitled cases are hereby published:
"On the other hand, the ruling of the Court of Tax Appeals to the effect that petitioner should pay legal interests on the amounts improperly collected from respondents is in accord with our decision in Carcar Electric & Ice Plant Co., Inc. vs. The Collector of Internal Revenue (54 O.G. No. 4, p. 1068). Resolving the Collector's Motion for reconsideration in said case, we held:
'We conclude that under the present Internal Revenue Code the Collector of Internal Revenue may be made to answer for interest at the legal rate on taxes improperly collected. Such liability serves as additional safeguard in favor of the taxpayer...
