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Republic of the Philippines v Marsman Development Co.; G.R. No. L-18956; 27 Apr 1972

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FACTS: In a letter dated 28 December 1954 under the signature of its counsel, Atty. Pedro Moya, defendant corporation acknowledged receipt of the assessments issued against it, requested to be furnished an itemized statement  of the said taxes with notice of its intention to question the validity and the legality of the assessments. In reply, the BIR told defendant corporation, among others, to make its request for reinvestigation or reexamination of tax assessments in writing under oath and to submit documents in support of the request. A series of exchanges between the two parties ensued with the defendant corporation not…

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