CIR v Union Shipping Corp. and CTA; G.R. No. L-66160; 21 May 1990
FACTS: Petitioner assessed private respondent for deficiency taxes due for years 1971 and 1972. Private respondent protested the assessment but petitioner instead issued on 25 November 1976 a Warrant of Distraint and Levy. The latter reiterated its request for reinvestigation of the assessment and for reconsideration of the summary collection through the Warrant of Distraint and Levy. Again without action on the request for reinvestigation and reconsideration of the Warrant, petitioner filed a collection suit against private respondent. Summons was issued against the latter on 28 December 1978. On 10 January 1979, private respondent filed its petition for review with…