Surigao Electric Co., Inc. v CTA and CIR; G.R. No. L-25289; 28 Jun 1974
FACTS: An exchange of correspondence between petitioner and the CIR ensued on petitioner’s liability for deficiency franchise tax, after the latter issued against petitioner a warrant of distraint and levy in November 1961 to enforce the collection of said franchise tax plus surcharge. Petitioner requested a recomputation of the 29 April 1963 revised assessment it received on 08 May 1963. When the CIR denied its request, it appealed to the CTA on 01 August 1963. ISSUE(S): Whether or not petitioner timely appealed to the CTA. HELD: NO. The letter of demand dated April 29, 1963 unquestionably constitutes the final action…