CIR v Hambrecht & Quist Philippines, Inc.; G.R. No. 169225; 17 Nov 2010
FACTS: On 04 November 1993, respondent received a tracer letter demanding payment of alleged deficiency income and expanded withholding taxes for the taxable year 1989. It filed its protest letter against the deficiency tax assessments on 03 December 1993. On 07 November 2001, respondent received a letter advising it of petitioner’s decision denying its protest on the ground that the protest was filed beyond the 30-day reglementary period prescribed in Section 229 of the NIRC. ISSUE(S): Whether or not respondent’s request for reinvestigation suspended the prescriptive period to collect deficiency taxes. HELD: NO. The mere filing of a protest letter which…