Fishwealth Canning Corp. v CIR; G.R. No. 179343; 21 Jan 2010
FACTS: Petitioner in a letter protested against the Final Assessment Notice (FAN) issued against it for deficiency income tax and VAT. Thereafter, it received on 04 August 2005 respondent’s Final Decision on Disputed Assessment (FDDA) denying the protest, apprising petitioner of its tax liabilities, and requesting the immediate payment thereof. It filed a Letter of Reconsideration on 01 September 2005. After respondent demanded payment of its tax liabilities in a Preliminary Collection Letter, petitioner filed a petition for review before the CTA on 20 October 2005. CTA dismissed the petition for being filed out of time. ISSUE(S): Whether or not a…