CIR vs kudos
COMMISSIONER OF INTERNAL REVENUE VS. KUDOS METAL CORPORATION G.R. No. 178087, May 05, 2010 Facts : 1. On April 15, 1999, Kudos filed its Annual ITR for the taxable year 1998. 2. Pursuant to a Letter of Authority dated September 7, 1999, the BIR, served upon respondent three Notices of Presentation of Records. 3. Respondent failed to comply with these notices, hence, the BIR issued a Subpeona Duces Tecum dated September 21, 2006, receipt of which was acknowledged by respondent's President, Mr. Chan Ching Bio, in a letter dated October 20, 2000. 4. A review and audit of respondent's records then ensued. 5. On December 10, 2001, Nelia Pasco, respondent's accountant, executed a Waiver of the Defense of Prescription, which was notarized on January 22, 2002, received by the BIR Enforcement Service on January 31, 2002 and by the BIR Tax Fraud Division on February 4, 2002, and accepted by the Assistant Commissioner of the Enforcement Service, Percival T. Sal...