J.B.L. Reyes

FACTS: During the period from 31 January 1951 to 08 June 1953, petitioner sold logs to Japanese firms. Upon ascertainment on 17 September 1957 that petitioner did not file a sales tax return and pay the corresponding tax on the sales, CIR on 27 August 1958 assessed against petitioner tax, surcharge and compromise penalty on its sales of logs for the said period. Petitioner averred that the filing of its income tax returns, wherein the proceeds of the disputed sales were declared, is substantial compliance with the requirements of filing a sales tax return. ISSUE(S): Whether or not the assessment…

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FACTS: Petitioner on 15 May 1951 filed his income tax return and paid half of the tax due assessed that same date by the CIR, leaving a balance which he offered on two occasions to pay out of his backpay. The CIR rejected both offers. On 30 March 1955, respondent issued a deficiency income tax assessment notice inclusive of petitioner’s balance from the 1950 income tax return plus surcharge. However, petitioenr claims to have learned of the revised assessment for the first time on 19 December 1956. ISSUE(S): Whether or not the government’s right to collect the balance has prescribed.…

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