=== PHILIPPINE INSTITUTE OF CERTIFIED PUBLIC ACCOUNTANTS ‘SEMINAR ON TAX UPDATES and COURT DECISIONS: ATTY, RAYMUND ,GALLARDO Holiday Inn &Saites Maka March 4, 2016, = igaz Phil —— 09.21.15) “Table Assessment” nota violation of the administrativedue ‘process requirement for validity of assessment ‘A“table assessment” which understood to mean an assessment derived without going othe place of busines the TP does no ‘olute Ts ight to administrative due process. What isimportantis TP wasgiven the opportunity ointligety cones: the assesment an submit documents insupport of hiarguments ‘What the law prohibits isthe absolute absene ofthe opportunity to behead 3/9/2016 RECENT 1. INCOME AND OTHER TAXES. EE. Phil Vs. CIR cra conn Torte defense of prescription to stand, TP must specifically © The TPhasthe burden asthe parry cntstng the aiity ofthe stsment, tosh which portion of ld deficiency tases pertain to the prescribed months © Mere alleaton that the iis, receipt, ax returns and other ‘oluminous records presented would ready show that there were ‘merous transactions during the quar period comer bythe szssment that had abeady prescribed without identiying which ofthe sid documents special pertain nde the months that Inne prescribed isnot sufcient. Inthe absence of proof, the ‘tire asessment is considered as pertaining to the unpresribed potion.3/9/2016 =. Phil, ere 21.15) a Cinemas vs. CIR Ctacase he 8551 10025) “TP cannot choose where to apply/eredit partial deficiency ‘tax payment "= The TP cannot invoke Article 1252 of the Civil Code (rule-on application of payments) to choose which debt the partial payment must be applied to, whether onthe principal or on the intrest. The government and the Cxpajer are not creditors and debtors of each other. There is a material distinetion between a tax and a debt. Debts are due 0 the government in its corporate capacity, while taxes are dueto the ‘government ints sovereign capacity. = Cinemas vs. CIR ctacase Sees (1002.15) ‘Oversatement of reported expenses subjected vo withholding tix peralphalit isnot equivalent to under declaration of ‘salesor income © Foran incometo be subject totay, there must be 1 gain orprofit i) the gan or profit must be realized; and fi ies noc exempted by law or treaty from income tax “Undeclared disbursement’, determined by comparing the amount appeating in the alphas against the amounts appearing inthe FSand the MTRis not undeclared income CUSKallowed asan expenseevenif notsubjected ro ‘withholding tax © Im order for the Cormmeon Usage Servise Area (CUSA) not to be subject to withholding tx, must fst be established that they srereimburvemeat of cual pens. Ina reimbursement act transaction, ii infsed thatthe expenses are incuted by the advancing party for the benefit and. account of the party Secommadsted. Hewever ether thn the biling statements ‘supposedly issued by the Lessor. other supertng documents Such a ales biling voices and offical receptor the tity providers shoud be presented that woul sufficient show that ‘what was actually paid is eactly the same amoune that was anced by the lessor. Simply pt, it must be proven that the ‘expense paid by the lesor were without any markup or prot ‘ment a Cinemas vs. CIR cTacae a 8551 10.02.15) Overstatement of reported expenses subjected to withholding, ‘ax peralphalist isnot equivalent tounder declaration of ‘sales orincome “+ Anassessment must be based on actual facts. A taxpayers five todeduct from its gross incomea lesser amount or not claim any deduction at all. Whats prohibited bythe income ‘ax law is toclaim adduction beyond the amount authorized therein. Hence, even granting that there isan undeclared disbursement, the sameis na prohibited by lw.= Cinemas vs. CIR ctaeise i (20.0215) Disallowance of NOLCO and MCITdoes not give riseto ‘deficiencyincome tax Under the Tax Code, compunies are ented t0 carey over et ‘eperatng los and deduct the same aginst their goss ieome for the next 3 comecatve year The same can only be the subject of ‘sesomemt when it iseaimed as deduction inthe suceeting3 years Sd nt inthe ear hen net ew nce, am District VS. CIR TA casero. 505/8575110:12.15) BIR Form No. 207 is necessary to prove the fact of withholding + Inthe li for excess CWT fin, BIR Form No 2307 ued by ‘the withholding agent must be presented to exablish the amet uid andthe ta wield fom tH cannot be replaced by ay ‘ther documentary evidence. Thus estimoniesas tothe estence fof the sid withholding tox starments (Le ICPA report, Arua TTR and judicial Afidavits) ae considered slServng without the tual presentation andidntifation of uch documents 3/9/2016 -: Cinemas vs. CIR = 8551 1002.15) Disallowance of NOLCO and MCIT does not give rise to ‘deficiency income tax “ MCIT maybe credited against the normal income tax for the 3 ‘immediately succeeding year. was improper to dsalow the sad MCIT and the excess MCIT cany-oer because any fax bereft Aerved by peitiner fom the carry-over of the said amounts ‘edounds to the suceading year Since theta lene wil ben the Suceedng yay, at most, ean only be assessed inthe sueccedng ear when te same were claimed 35 deductions or when the the benefits were. = Mobile vs. IR — 45) ‘The 50% expense disallowance “ Best Evidence ‘Obtainable" valid if the amount cannotbe ascertained * Conditions forthe deductibity ofexpenees. ‘eornaryand necessary 2: pid or nerd within the taxable year 5 Incurred incarying on rade or basnes substantiated Stan required tobe deducted and with there rom has ‘een pa tothe Bureau of Incemal Revenue.Ee Mobile vs. CIR ct sen ae 103445) ‘The 50% expense disallowance "Best Evidence ‘Obtainable’ valid iftheamount eannot be ascertained «Exception to the‘substantiaton” requirement here 2 showing tat dhe expenses had been incured but the ‘act amount cannot be sscenained due to the absence of docueeary evidence, its the duty ofthe BIR co rake an ‘estimate ofthe deduction that maybe allowed in computing for the taxpayers axabl income. The diallowance of 39% ofthe taxpayer claimed deduction is ald under Se, 24 (€) of RMC 23000. = International_vs. CIR CtA.case no. 8535(11.4.15) Tass for thes preferential ax of PEZA locators © For purposes of computing the 53 preferential tax of a PEZA. locator, roat lesrevenu may be reduced only by sles iscounes, sles returns and allowances, cost of sales or dret ‘ints o an ofthe enumerated allonable deductions under RR 2005 Hence, in determining wheter acs pat of cst of gods {manubtured and sold, sid cost ens be atebutable 9 the PEZA registered prduetorgnods ofthe tpayer In substaiating the claimed vee costs, accounts payable souchers accompanied by offal recepts of supplies are ‘evidence ony of the fct of payment but do not establish the Connection of the costs inured to the tapayers repitered SctvtesThe Terme and Conditions of the PEZA Registration ‘Agrement is reguted t9 prove that the costs incted are nuibutable tothe PEZA- registered products or gods 3/9/2016 EE mnal_vs. CIR CA case no. 8535(23.4.35) PEZA Enuty subject 05% GIT maybe subject to DST “While emmption fom DST is acknowledge, whenever one party 10 the table document enjoys exemption fom fx, the Other party who s noc exempt shal be the one fable the DST: + In this case the lessor = the otherconractng party tothe esase agreement should have been the ane lable foe the DST the PEZA ‘ster elit filed tshow copies of DST returns ied by and prymentecits ofthe lessor, n which ase the Cour ruled that {he DST shouldbe assessed guia the PEZA soir eit. = Azucarera Sa no, 8459) 11.23.18) DST computation based on year-end balances is oid + DSTon intercompany advances shouldbe based only on the amounts representing new transaetions oF transactions entered into by the taxpayer during the year (year under Jvestigation) and no the torl year-end balances. DST is assessed ona per transaction bas‘Central Azucarera vs, CIR Ca cove no. 8459( 1.23.15) Tmpositon of compromise penalties without conformity of the TP isllegsl and unathoried rales are only amounts suggested in setemet ly, and may not be impased or exacted on the he even thatthe aspayer fest pay these, + teiswellstded chat payment of eompromize penalties should not be compelled upon the taxpayer because by Hs Yery nature, i implies 2 mutual sgrement between the paris with respect 0 the thing oe subject matter tht Ising compromised, andthe ‘choice of paying or not paying the perly disney Belongs to the taxpyer. The imposition of the sare without the conformity ‘ofthe taxpayer illegal and unauthorized. CENT COl Il. VALUE ADDED TAX 3/9/2016 “CIR. Shinko Industries cra E8 casero. 11 (2.4.16) Representative Office not tobe treated as ROHQ for tax Purposes “The phase "prometion af the parent companys products, quay contol of products" in Shnkas SEC Registration which the BIR has anchored is indngs that indeed Shino tam RON should ‘ot make ita sales fice or equate it tothe qualifying series de by ROMs such a5 marketing contol ad sales promotion, fs well a research and. development service and product development, - Phils. vs. CIR CTA EB.ase no = 30.145) Judicial appeal to claim VAT refund can also be filed ‘within 30 days after the lapse of 120 days from submission of “complete documents” “The term “complete documents” may’als be interpreted to sncan “relevant supporting documents” which are documents necessary to support the aplication for refund ‘or TCC as determined by the taxpayer. Thus, ifthe taxpayer decides co submit only certain decuments or should the taxpayer fal, or opt not to submit any document at all, in support of its application for refund or credit, then the reckoning date of the 120 diy period should be from the of thesaid application= Phils. vs. CIR CIA eB case Bh 2153101415) Taput tax carried over from previous period should also ‘be substantiated to beallowed «Although i is tue that the Court isnot strily goveraed by technical rules of idence, the inoicing apd substanaion equiments under the VAT lav must, nevertheless, be flawed. Tecaueltis the only wayto deter dhe veracity of poner’ clan. = 5a Pag-unlad vs. CIR cts Oar 1029.5) Microfinancingis Subject to VAT «Wie eis re that ee onanization not onpnized for prot but opted ealsiely forthe promotion of soil well i cep lem income tas the sme isnt te with respect tthe ‘VAT. Any pesonvwho makes 2 practice of lending money oe themselves o thes at interests considered a lening investor subject tothe VAT “in adaton, the taxpayer ld to prove that i has been authorized by the BSP o perform quas-barking functions, hence ireanot be considered 2 falling under the definition of “rhe ‘Non-Bank Financial Intermediary” whos transitions are exempt fiom the VAT 3/9/2016 aor beer 36) Sales to COMELECare Zero Rated © Sales to COMELEC ate zero rate pursuant t0 See 108 (B) 3). "Services rendered operons oe entities whose exemption wider special laws or interational agreements to which the Philippines ‘Sa signatory efetvely subjects the supply of such serves 0 ero percent rte Sec 12 of RA 0369, amending RA No. S436, ented “An Aer Authoring The Commision On Elections To Use An Auemated lection System in the Mey 1998 Naina Local Hetons and In Sulsequent Notional and Covel Ector Exercises provides that “the Commission is authorized (@ procure, in sccondance with existing laws, by purehate, lake, rent oF other forms of acquisition, supplies, equipment, materials, Software, faclties and other serves, from local or foreign sources free fom axes and import dalies 3". z= sa Pag-unlad vs. CIR_Ca 1 er 1029.15) ‘Micro financingis Subject to VAT ©» The taxpyer.aet of lending money and eaming iret makes it 4 lending Imestor subject to VAT even if the mlerinancing inaiduion enages in lending money to the poor oF fn socal lending activites. Sec 8 of the Tax Code dots not distinguish between microfinancing and commercial lending; neither i micrfinancing treated 3 vateaemp transaction under se. 09, ofthe Tax CodeWc ceeeeoe Sales to PAGCOR are Zero Rated, "is been stein the case of PAGCOR vs. BIR hat PAGCOR is ‘ot liable to VAT, Although i hasbeen exclude frm the tof *pecifcgoverment institution hat are exempt fom income tax tuhdr See 27 (C) ofthe Tax Code, es stl expe om tases under its Charter, Under the premises, petitioner’ transactions With PAGCOR are subject o VAT at zero ate aling Under ervies performed by VAT registered persons to persons oF ets whose ‘temption under special law or temational agement to which the Philippines i signtary efeely subjects such supply of secvcest0 OF rate. —Chevron Phils. s. CIR scan ne 235) Fxcsable products petroleum) sold wo taxexempt tenitiesallows the sellerto refund excise tax paid on theimportation ormanufacture of product sold etcleum products sll to entities that ae by aw exept fromm fet and inde: tases ar exert fom exis 2x As Sch, the facie ax an the product was ace passed onthe exempt buyer ‘when sold by importer ofthe exciable pect. Ths the entity ‘who has the right o cam refund or tax credit onthe excise tax fil the statutory taxpyer inasmuch a the ability forthe pyment of the ete tax accrue! immediately upon ie Innporation. 3/9/2016 JPRECENT COURT DECISIONS — IIL. TAXPAYER'S RIGHTS AND REMEDIES. -- vs. saa = SC GAN ee 15) Petition filed before the CTA can no longerbe withdrawn, ‘even if administrative claim for refund/TCC has been decided + Rl 0 ofthe Rles of Court state that when the cae deemed ‘submitted for reoltion, withdrawal of appels made aftr the Fling ofthe apple's brie may stil be alowed atthe discretion ofthe court3/9/2016 = pi 9.16.15) —CIR vs. Nippon Express S€GR No. 2129201 5.1615) Pafition filed before the CTA can no longer be withdrawn Petition filed before the CTA can no longer be withdrawn even ifadministrativeclaim for refund/TCChas been even if administrative claim forrefund/TCChas been decided decided + However, ule 0 ofthe Rules of Court cannot be applied when + However, Ruleso ofthe Rules of Cour cannot beappled when: «a fll own bearing ha already been conducted ad the = theinteres of thegpvermment aed moresgiicanth the parties had alaady vented thee claims, Thus, the findings publi il be greatly prejudiced if motion to withdraws ontained therein were the rests of an exhaustive sty ofthe ‘rate as thee sem to bean ent in thecaeuaton of the plesding ns jdeios valuation of the evidence sbnted by Fefund under the adminis claim the partes. as well asthe report ofthe commissioned certified pubbe accountant © Inmatters of aration, the government cannot be estopped by the mistakes, ears or omisions ats get pone ‘epends the ably ofthe overnent toserve the people or ‘whoae Benet aes te calcd ‘Theresa massive discrepancy between the administrative and jc determina -= Mobile vs. CIR es 45) Ee Inc vs. CIR CTAACNo RES ‘The right ofthe taxpayerto respond tothe PAN ian Assessment resulting from surveillancets nota final important part of the due process requirement “decison appealable withthe CTA © Section a8 ofthe NIRC of 199, as amended and RRNa 299, specifically Seton 3.2 presrbe a fiten (dn prod rom reecipt ofa PAN within which a taxpayer may respond thereto, Procedural due proces i ot satisfied withthe mete issuance of © Section 7oF RA. Naga, amending RA No.125,the Law Creating the CTA provides that the jurisction ofthe Courts not nine othe decisions orlings ofthe CIR but also PAN without ging the taxpayer an opportunity to respond inches the inaction ofthe tet. The decisions ings or thereto Insetion ofthe Commissioner are necessary inorder test the “© Bven if an opportunity to protest the FLD was acconed the Court of Tix Appl with jardin to entertain the appeal. taxpayer, it does not eure the fatal inemity of wantonly dsrgatding patitione’s ight to be heard with regard to is Potions or amuments paint the PAN, 2 viobtion of Prtioners right to due process © Theappelable dein contemplated in RA. sta5isome which ‘onstttes final decbionof the CI. Theassesmentanived at resulting from surellnce is notanapplable decision fr there Iso dispated assessment yet.- “WGC, Inc_vs. CIR CTAACN. eens 7.15) Nullifiation of closure ordersissted by ther BIR should ‘beappealed to the CTA and not tothe RIC + The jualin af the CTA inclds “other mates” which ref to those cases which donot necessrily invoke dnpted _xsessments or tefl Bal controversies arng under the Tax Code or other laws administered by the IR. “+The power to suspend the business operations of a txpayer, is covered within the meaing of other matters sing under the “Tax Cade or aher ls administered bythe Beat of Interal Revenue which tundeh juridiction ofthe Court. + Inn, lication af ose onder issue by cher BIR should ‘eappealed tothe CTA and not othe Regina Tal Court -E s. Masin-Aes Pte a 201 10278.15) ‘$C minute resolution does not prevent retroactivity ofa later ‘decision The doctrines or principles of law which constitute binding precedent are embosied in decisions by the Supreme Cour, noe Inits minute reson "The transaction a issue happened in 20 where the Mint case requiring 3 prior application of TTR with the BIR before one can referential a eat tes + Alvorable decision under the Detache bank css can retoat to cover the instant eve 3/9/2016 ~= Masin-Aes Pte Ltd TA SMES 3201 (20.2815) '8C minute resolution does nt prevent retroactivity ofalater decision The Minute resolutions issued by the SC in the case of Mirant (GR, No. 16853, Nov 3007 ad Feb 3008) which equved a prior application for tax treaty rele before a taxpayer can aval of the referential tax treaty are not binding precedents and cannot bind on-pates othe action. They ae binding ony with respect 0 fases with the same subject-matter and the same issues Concerning he same pasties A minute elution may amount 12 fal ation on the ase but 'Snataprecedentand cannot bind non-paiesto the action - Central Azucarera vs. CIR Cra Ho 8859 (1123.5) Requisitesof of valid waive Valid frm The phase filled vp. 2 Signe by the tapayer ora duly authorized representative, Wa corporation, itshould be sgn by any fs responsible slic delegated, dhe concerned revenue oficial shallsee Fethat sich delegation isin writing and duly notarized. 2 Signd by the CRor revenue oficial authorized 4 Both the date of execution by the tanpayerand dat of acceptance by the Bureau shouldbe Bere the expiation ofthe period of prescription or blo the se ofthe period ace pan ees nbiequent agreement eseeted i nc afier_19__"should beCentral Azucarera vs. CIR CTAWo. 6459 11.23.15) Requisitesof ofa valid waiver: Wave executed in copies “6. The WAIVER" should not be accepted by the concerned BIR office and ofa unless duly notarized, ‘Noce: The notary publics nora commision ust be aid at thetime of notation isthe BIRsebigation ensure propernotrzation ofthe waiver Improper aotrived Aocurents do aot enjoy the presumption of dae execution and authenticity. Presumpeions that atach 0 notarized documents ‘an beafirned oly ln ass beyond dispute that he notarzation was el ae - vs. Next Mobile SC 6. No. 212852. 12..15) When both parties are at fault in the execution of the waiver, waiveris considered valid. Reasons for valdacing an inal waiver 1 Paris inthis easeare in pari det or "in qual fal Paris mast come to court wth clean hands >. Taxpayer is estopped in questioning the vat ofthe waiver since it allowed the BR co rely on them and didnot raise any objection agains theirvabity unl taxpayer wasassessed, 4. Teypayer afer yolunarily evceting waivers, insisted on thei malty by sing the very same defectsit caused. BIR, onthe ther hind, miseabh fled t eae om taspayer compliance With is rls. BIR was negligent amounting to malice and Bad Faith lle taxpayer was abo at ful in comping with the oqitements amounting Hkewise tad fh, 3/9/2016 Ee ‘CiRs. Next Mobile SC GR. Wo. 21285212715) ‘When both parties are at fault in the execution of the waive, itis considered valid. Both paris are a¢ fue in eaccuting the Waivers because of the {along fs: (0 they wereexecuted without notaried boat autos: 1) te dates of acceptance bythe BIR were not indicated therein snd 10) the fact of receipt by respondent of its copy of the Second iar was not indicate on the lace of the original Second Waiver - Total Gas vs. CIR SCa. No. ara “The submission of documents is deemed ‘completed for purposes of determining the running of the 10-day period is ultimately determined by claimant-taxpayer «© therule in determining when documents submited are deemed ‘eomplt” so days fom the date an administrative claim for excess utilized VATis ied unless given Frter extension by ‘the CI. Upon ili by the taxpayer f his complete documents to Suppor hisappliation, or expration ofthe period given, the CIR Jnastao days within which o decide theclaim fora red or ‘refund. Should the taxpayer onthe dat of his lag, manifest that hen longer wishes to submit any ether addition document tocomplete hi administratve cam the 20 dy period allowed to te CIR begins torn frm the date of ing (RMC 49-2003 relation 0 RA8424) 10- Total Gas vs.ciR ae “The submission of documents is deemed ‘completed for ‘purposes of determining the running of the r20-day period is ultimately determined by claimant-taxpayer © Thedocumentsare actualy eomplteas required by aw stor the CR and the courts to determine, “In all cases, whatever documents 2 taxpayer imende to Fle to suppor his chim mast be completed within the evo-yar period Under Seti aA) ofthe NIRC. The 30-day period fom denial ‘of che cm or rom the expiration ofthe 120-ay petiod within ‘which to appeal the dena ee acon ofthe CIR othe CTA must kobe nspece = ‘vs. Docena CTA EB crn No 30(1.4.16) “Willful non payment of tax due will render the corporation's responsible officers Hable under Sec. 353 and 256 ofthe Tax Code In determining whether the tax Habliy of a corporation shoud be extended 0s responsible oficers, the act of rom pyieat ofthe tax ‘ust be wil “ Tobedeemed actimioal act under Sa. 25 the Tax Code theact of ‘nonpayment oft must be wilf a wolneary intentional vilton of a Known legal dy, Wilfuhess implies the existence of nowedge” and “voluntrins ithe taxpayer is avare of his ax ability bue vohutarly and otentionally etwsed to pay the tax Tabi. © Thee tha the accused acted in goo faith and with best efor to comply with the demand to ay the deficiency tae wil show absence of the element of illness 3/9/2016 » Total Gas vs. CIR SC 6. No. 207312 (328.15) “The submission of documents is deemed "completed for Purpores of determining the running of the 120-day period is ultimately determined by claimant-taxpayer However, upon the isuance of RMC 5-201, the reckoning of ‘he day period is now at the ime on ies his elim sine the taxpayer dlamant i now required c complete his supporting documents and attest that he wil no longer subi any other document to prove hisclsim. Further, the rxpayerfsbared fom satin, ational acme afer he as ed hs » —— People vs. Dacena a Willfal_ non payment of tax due will render the «corporation's responsibe officers liable under See. 253 and 256 of the Tax Code + wlfuiess must be presen Beyond reasonable daub. I isnot pen the accused to prove his innocence. Rather, ic is the ‘Bligation of the prosecution t show with mom certainty and through is own evidence, thatthe accused is guiky of the criminal charges + For Blur af the prosecutor to present prof of wiles the lb ofthe corporation cannot extend toitscorporate aie. rT3/9/2016 = ai ng es (14.19 - Land Bank vs. CIR CTA} en 2149 “ATAN i validly issued ifthe registry return cardi signed by TPs authorized representative or a certification by the Bureau of Posts that mail was served upon TPs authorized representative is issued IF he tapayer denis the receipt ofthe FAN, itis sential forthe ‘ito prove te ct of ming hugh dhe regsty eceip sued by the Bore of Posts or the rey etarncard signed by the taxpayer representative ora etalon sed by the Bare of Ponts that the mail matter was served upon the TPs authorized representative. isnot enough that he reityzeturn card was presented by the CIR. Sach should have been signed by the tanpayrsautoried presenti (CTA has jurisdiction over tax abatement cases and filing judicial appeal must not be beyond the 30 day period from receipt of final decision ofthe BIR + Teeslusive jurisdiction ofthe CTA is conferred by R35, Sec7 which provides: * Decisions of the CIR in cases icvohing disputed assessments refund of inzerna enue ates fees, o other charges, penal: in selon thereto, or other matters arising under the NIRC or ‘thers adminsered bythe BIR” « Theleter denial ofthe equest for recosidertion and indicating therein that he persis be pi within 1 days rr receipt of notice constitute a he final Jeteination of the matter which ‘an nos be fle fo judicial review within 3 days fom receipt thereot - Qatar yi CR CTA ne on ONETT Computation Sheet is not equivalent to FAN that requiresa letterof protest © While the Onett computation sheet states the computation ‘of ta iblities, which the P is required to pay, it dos not formally inform the taxpayer ofits tx abies and there is no formal demand t pay the same, Without the formal ‘demand for payment, the taxpayer has no way fo determine the period within which to protest the tax ability Ate al, the issuance of an assessment is vital in determining the pet of limitation regarding ies proper isance and the peti within which to protest -_ vs. Joel Mendez ct ¢ nu Requisites to be charged under See 255 of the Tax Code for failure to filerecurn, pay, withhold and remit axes : 1 That che accused was a person requited to make or file a © That he fled to make or fle such vecurn a¢ the time required by law + That che failure to make o fle the eeurn was wlll 123/9/2016 = vs Joel Mendez: oa on 23036) — Acted was fund tobe in voaton of Sec 355. | Evidence would revel that accused had buen inthe practice of proeson aa doctor fering medial sevice as etl as 695. ‘Advertisements to pramote the srvices were made negating ets ree eral ented ee 1 proton stent THANK YOU! 2 Aeced cied that his ei wer ie cle. The geeceact nec taconite eg talTh Dosa eee Sic maar s conepening day toi Ree ee 5 Aecast nas gion nos and oppiunis by the DIR {Aria SONGCO and ASSOCIATES including requ fOr submission of books to refute x ‘es i ale a se decent ndings basco led okay ston onthe veo i, at ication his intent to def the Goverment. ‘ela one Mime oegiancom 13