ATENEO DE MANILA

UNIVERSITY SCHOOL OF LAW

COURSE SYLLABUS

Course Title: TAXATION II Instructors:

No. of Units: 3 units Atty. Terence Conrad H.
Bello
Semester/ SY: 3rd Year, 1st Semester
Department/Track: Taxation Law
Pre-requisites: Persons and Family
Relations, Corporation Law,
Property, Taxation I,
Succession

I. COURSE DESCRIPTION AND OBJECTIVES

The course studies the concepts and general principles of transfer (estate and donor’s),
value added, excise, and other percentage and miscellaneous taxes, including documentary
stamp tax, provided in the National Internal Revenue Code; the remedies available to the
government and the taxpayer; fundamentals of local taxation; both under the Local Tax
Code and Real Property Tax Code; and the general principles on tariff and customs duties.

Upon completion of this course, students will be able to:

• Comprehend the general principles and forms of taxes provided in the National
Internal Revenue Code and other pertinent laws
• Apply the taxation laws to certain set of facts and analyze its merits and possible
outcomes
• Evaluate tax options and fiscal remedies available to the government and the taxpayer

Methodology

The course will employ recitation as the primary method of instruction, to develop the
students’ power of analysis, reasoning, and facility of expression. The students will be
asked to answer questions, based on assigned legal provisions, court decisions and other
readings, to stimulate critical thinking and enhance their communication and
argumentation skills.

II. COURSE OUTLINE

Week/Session Topic
Week 1 RIGHTS AND REMEDIES OF THE GOVERNMENT
UNDER THE NATIONAL INTERNAL REVENUE CODE
I. Examination and Audit of Returns
A. Statutory Basis
II. BIR’s Investigative Authority
A. Statutory Basis
1. Administrative Summons to Taxpayer
2. Third-Party Summons
 B. Informer’s Reward
III. BIR’s Power to Make Assessments
A. Upon Examination of Returns Filed
B. In Case of Failure to Submit Required Reports
C. After Inventory Taking or Surveillance
D. Where CIR Terminates Taxpayer’s Taxable Period
E. Prescribe Zonal Values
F. Issuance of Pre-Assessment Notice
G. Issuance of Final Assessment Notice
1. What Constitutes an Assessment
2. Presumption of Correctness of Assessment
3. Assessment Must be Based on Actual Facts
4. Assessment Issues Outside Scope of Letter of
Authority
Week 2 IV. Collection of Unpaid Taxes
A. Distraint, Garnishment, Levy and Seizure
B. Civil Action
C. Criminal Action
D. Anti-Injunction Rule
1. General Rule
2. Exception
E. Nature and Extent of Tax Lien
F. Compromise and Abatement
V. Imposition of Surcharge, Interest and Compromise Penalty
A. Civil Penalties
B. Interest
C. Compromise Penalty
Week 3 RIGHTS AND REMEDIES OF TAXPAYERS
UNDER THE NATIONAL INTERNAL REVENUE CODE
I. Amend Tax Return
II. Protest Assessment
A. Procedure
B. Preliminary Assessment Notice (PAN)
1. Exceptions
2. Effect of Failure to Receive PAN
C. Final Assessment Notice
D. Requirement to Inform Taxpayer of Factual and Legal
Basis of Assessment
E. Submission of Supporting Documents
1. Effect of Non-compliance
2. What Constitutes “Relevant Supporting Documents”
F. Effect of Failure to File Protest
Week 4 III. In Case of Denial of Protest or Inaction, Appeal to CTA
A. Scope of Jurisdiction of CTA/ What is Appealable to
CTA
B. Applicable to 180-Day Rule
C. What Constitutes Denial of Protest/ Decision on
Disputed Assessment
1. General Rule
2. Issuance of Revised Assessment Upon Reinvestigation
 3. Final Notice Before Seizure
4. Final Demand Letter
5. Filing of Collection Suit
6. Issuance of Warrant of Distraint and Levy
D. Period to Appeal/ Effect of Failure to Appeal
E. Mode of Appeal and Effect of Appeal
1. Appeal to a Division of the CTA
2. Appeal to CTA En Banc
IV. Appeal to Supreme Court
Week 5 V. Refund and/or Tax Credit of Erroneously Paid Tax
A. What Constitutes Erroneous Payment
B. Requirement of Filing Administrative Claim
C. Exception to Requirement of Filing Administrative Claim
D. Effect of Supervening Event
E. Offsetting Against Deficiency Tax Assessments
F. Whether Government is Liable for Interest, Attorney’s
Fees, Etc.
G. Taxes Not Subject to Set-Off
VI. Appeal in Case of Denial of Refund/ Tax Credit Claim
A. Court of Tax Appeals (Division and En Banc)
B. Supreme Court
Week 6 VII. Appeal of Interpretative Powers and Decisions on “Other
Matters” Arising Under the NIRC
A. Power of Review of DOF over Rulings
B. What is Covered by “Other Matters”
1. In General
2. BIR Issuances
VIII. Statute of Limitations
C. Period to Assess
3. When is an Assessment Deemed Made?
4. Effect of Filing an Amended Return
5. Effect of Filing a Wrong Return
6. How Prescriptive Period Counted
7. Ordinary Prescription
8. Extraordinary Prescription
a. False/ Fraudulent Return or No Return
b. Waiver of Prescriptive Period
c. Suspension of Prescriptive Period
D. Period to Collect
E. Period to File Protest
F. Period to Appeal Decision on Disputed Assessment to
CTA
G. Period to File Refund or Tax Credit Claim
1. How Two-Year Prescriptive Period Counted
H. Period to Prosecute Violations of any Provisions of NIRC
IX. Non-Retroactivity of Revocation of Rulings or Regulations

Week 7 MIDTERMS
Week 8 ESTATE TAX
I. The Gross Estate
 A. Introduction
B. General Definition of Gross Estate
C. Constitution
1. Property in Which Decedent Had an Interest
2. Transfers in Contemplation of Death
3. Transfers Taking Effect at Death
4. Transfers with Retained Interest
a. Period for Which Interest is Retained
i. For life
ii. For any period which does not in fact end
before death
b. Nature of Interest Retained
i. Possession or enjoyment
ii. Right to income
iii. Right to designate person who shall have
possession or enjoyment
iv. Right to designate person who shall receive
income
5. Recovable Transfers
a. Nature of Power
i. Power to alter or amend
ii. Power to revoke
iii. Power to terminate
b. Meaning of Power in “Whatever Capacity”
c. Meaning of Power Exercisable in “Conjunction with
any Other Person”
d. Meaning of “Relinquishment of Powers in
Contemplation of Death”
6. Power of Appointment
a. Meaning of “Power of Appointment”
b. Applicability in the Philippines
7. Proceeds of Life Insurance
a. Estate as Beneficiary
b. Third Person as Beneficiary
II. Valuation of Estate and Amount to be Included in Cases Covered
by Secs. 85 (B), (C) and (D) of the NIRC
III. Exempt Transfers
IV. Exclusion of Conjugal Shares of Surviving Spouse
Week 9 V. Deductions from Gross Estate
A. Expenses, Loses, Indebtedness, Taxes, Etc. (ELITE)
1. Funeral Expenses
2. Expenses for Testamentary of Intestate Proceedings
3. Claims Against the Estate
4. Claims Against Insolvent Persons
5. Unpaid Debts/ Mortgages
6. Losses
B. Vanishing Deduction
C. Transfers for Public Use
D. Family Home
E. Standard Deduction
 F. Medical Expenses
G. Retirement Benefits and Separation Pay under NIRC §
32(B)(6)(a) and (b)
VI. Foreign Tax Credits
A. Per Country Limitation
B. Global Limitation
VII. Special Rules for Non-Resident Aliens
A. Meaning of Resident or Non-Resident
B. Inclusions in Gross Estate
C. Deductions from Gross Estate
D. Foreign Tax Credits
E. Estate Tax Return
F. Payment of Estate Tax
G. Consequences of Non-Payment of Estate Tax

DONOR’S TAX
I. Meaning of “Gift”
II. Valuation of Gifts
III. Transfer for Less Than Adequate Consideration
IV. Exempt Gifts
V. Foreign Tax Credit
A. Per Country Limitation
B. Global Limitation
VI. On Whom Imposed
VII. Administrative
A. Tax Rates
B. Donor’s Tax Return
C. Payment of Donor’s Tax
D. Consequences of Non-Payment of Donor’s Tax
Week 10 VALUE-ADDED TAX
I. Taxable Transactions
A. In General
B. Sale of Goods or Properties
1. Transactions Covered
a. Actual Sale
b. Transactions Deemed Sale
c. Changes in or Cessation of Status of a VAT-Registered
Person
2. Taxable Base
a. Gross Selling Price
b. Sales Discounts, Returns and Allowances
c. Taxable Base for Transactions Deemed Sale and Below
Market Gross Selling Price
C. Importation of Goods
D. Sale of Services
1. Meaning of “Sale or Exchange of Service”
2. Taxable Base: Gross Receipts Actually and Constructively
Received
a. Amounts Earmarked for Payments to Third Parties
b. Reimbursement of Expenses
 II. Relief from VAT: Zero-Rating and Exemptions
A. Difference Between Zero-Rating and Exemption
B. Automatically Zero-Related Transactions
1. Sale of Goods and Properties
2. Sale of Services
3. Meaning of “Accounted for in Accordance with the Rules
and Regulations of the BSP”
C. Effectively Zero-Related Transactions
1. Sale of Goods and Properties
2. Sale of Services
D. Exempt Transactions
1. Coverage of Exemption
a. General Rule
b. Exception
2. Waiver of VAT Exemption/ Election to be Subject to
VAT
III. Rates of VAT
A. For Output Tax
1. Standard Rate – 12%
2. Zero-Rated Transactions – 0%
B. For Input Tax
1. Standard Rule – 12%
2. Zero-Rated Transactions – 0%
3. Transitional Input Tax – 2% or actual VAT paid,
whichever is higher
4. Presumptive Input Tax – 4%
5. Final Withholding VAT on Government or GOCC’s –
5%
Week 11 IV. Tax Credits and Refunds
A. Input Tax Credit
1. Persons Who Can Avail of the Input Tax Credit
2. Special Rules on Amortization of Input Tax on
Depreciable Goods
3. Special Rules on Apportionment of Input Tax on Mixed
Transactions
4. Substantiation of Input Tax Credits
B. Transitional Input Tax
C. Presumptive Input Tax
D. Final Withholding VAT
E. Claims for Refund or Issuance of Tax Credit Certificates
1. Zero-Rated or Effectively Zero-Rated Transactions
2. Cancellation of VAT Registration
3. Period within which Refund or Tax Credit of Input Tax
shall be made
V. Compliance Requirements
A. Registration with the BIR
1. Mandatory VAT Registration
2. Optional VAT Registration
3. Consequences of Failure to Register as a VAT Person
4. Cancellation of VAT Registration
 B. Record Keeping Requirements
C. Invoices and Receipts
1. General Requirements
2. Invoicing and Recording of Deemed Sale Transactions
3. Consequences of Erroneous Issuance of VAT Invoice or
O/R
D. Creditable Withholding Tax
VI. Filing of Return and Payment of Tax
Week 12 OTHER PERCENTAGE TAXES
I. Persons/ Transactions Subject to Percentage Taxes
A. Persons Exempt from VAT
B. Domestic Carriers and Keepers of Garages
C. International Carriers
D. Franchises
E. Overseas Dispatch, Message or Conversation
F. Banks and Non-Bank Financial Intermediaries
G. Finance Companies
H. Life Insurance Premiums
I. Agents of Foreign Insurance Companies
J. Amusement
K. Winnings
L. Stock Transaction in Philippine Stock Exchange
II. Returns and Payment of Percentage Tax

EXCISE TAX
I. Goods Subject to Excise Tax
A. In general
B. Alcohol Products
C. Tobacco Products
D. Petroleum Products
E. Miscellaneous Articles
1. Automobiles
2. Non-Essential Goods
F. Mineral Products
II. Payment of Excise Tax
III. Administrative Requirements

DOCUMENTARY STAMP TAX

I. In General
II. Transactions/ Documents Subject to DST
A. Original Issuance of Shares
B. Transfer of Shares
C. Foreign-Issued Bonds, Debentures, Shares or Certificates of
Indebtedness, and Other Instruments
D. Issue and Transfer of Certificate of Interest in Property or
Accumulations
E. Bank Checks, Drafts, Certificates of Deposit not Bearing
Interest
F. Debt Instruments
G. Bills of Exchange or Drafts
 H. Acceptance of Foreign-Drawn Bills of Exchange
I. Foreign Bills of Exchange and LC’s
J. Life Insurance Policies
K. Non-Life Insurance Policies
L. Fidelity Bonds and Other Insurance Policies
M. Annuities and Pre-Need Plans
N. Indemnity Bonds
O. Certificates
P. Warehouse Receipts
Q. Jai-Alai, Horse Race, Lotto, etc.
R. Bills of Lading or Receipts
S. Proxies
T. Powers of Attorney
U. Lease of Real Property
V. Mortgages, Pledges and Deeds of Trust
W. Deed of Sale of Real Property
X. Charter Party and Similar Instruments
Y. Assignment, Transfer, and Renewal of Certain Instruments
III. Transactions/ Documents Not Subject to DST
IV. Payment of DST
V. Effect of Non-Payment of DST
Week 13 LOCAL TAXATION
I. General Principles
A. Local Autonomy
B. Fundamental Principles
C. Common Limitations on Taxing Powers of LGUs
II. Scope of Taxing Powers of LGUs
A. Province
B. Municipality
C. City
D. Barangay
III. Community Tax Certificate (CTC)
A. Who are Liable
B. Exemptions
C. Place and Time of Payment of Tax
IV. Time, Manner and Place of Payment of Local Business Tax
A. Time of Payment
1. General Rule
2. In Case of New Ordinance Levying New Tax or
Increasing Rates
3. In case of Retirement of Business
B. Manner of Payment
C. Place of Payment
1. Location of Branch or Sales Outlet
2. Allocation to 2 or more LGUs
3. Sales by Route Trucks or Vans
V. Enactment of Tax Ordinances and Other Revenue Measures
A. Public Hearing
B. Publication
C. Appeal to Secretary of Justice
 D. Appeal to Court of Competent Jurisdiction
E. Effect of Appeal
VI. Remedies of Local Government and Taxpayer
A. Remedies of Local Government
1. Examination of Taxpayer’s Books of Accounts
2. Issuance of Deficiency Assessment
3. Imposition of Surcharge and Interest
4. Summary Remedies
a. Distraint of Personal Property
b. Levy on Real Property
c. Further Distraint and Levy
5. Judicial Remedy (Collection)
B. Remedies of Taxpayer
1. Protest of Assessment
2. Claim for Refund or Tax Credit
VII. Authority of LGUs to Grant Tax Exemption Privileges

REAL PROPERTY TAXATION

I. General Principles and Definitions
II. Real Property Tax and Additional or Special Levies
A. Basic Real Property Tax
B. Special Education Fund (SEF)
C. Tax on Idle Lands
D. Special Levy Due to Improvements
III. Exemptions from Real Property Tax
IV. Payment of Real Property Tax and Special Levies
A. Date of Accrual
B. Payment on Installment
C. Discount for Advance Payment
V. Appraisal and Assessment of Real Property
A. Appraisal
1. Voluntary
2. Involuntary
B. Assessment
1. Classifying Real Property
2. Assessment Levels
3. General Revision
4. Reassessment
VI. Remedies of Local Government
A. Posting of Notice of Delinquency
B. Imposition of Interest
C. Judicial Action (Collection)
D. Unpaid Tax Constitutes a Lien
VII. Remedies of Taxpayer
A. Dispute Assessment
1. Appeal to Local Board of Assessment Appeals
2. If denied, appeal to Central Board of Assessment Appeals
3. If denied, appeal to Court of Tax Appeals
4. Effect of Appeal
B. Payment under Protest
 C. Claim for Refund or Credit

TARIFF AND CUSTOMS CODE

I. Introduction
A. General Rules for the Interpretation of the ASEAN
Harmonized Tariff Nomenclature (AHTN)
B. Rates of Import Duty
C. Rate of Exchange
D. Imported Articles Subject to Duty
E. Conditionally-Free Importations
F. Prohibited Importations
G. Articles Entitled to Duty Drawback
II. Basis of Assessment of Duty
A. Basis of Dutiable Value
B. Basis of Dutiable Weight
III. Special Duties
A. Anti-Dumping Duty
B. Countervailing Duty
C. Marking Duty
D. Discriminating Duty
IV. Ascertainment and Collection of Import Duty
A. When Importation Begins and Deemed Terminated
B. Who is Deemed Owner of Imported Articles
C. Liability of Importer for Duties
V. Remedies of Government
A. Search, Seizure and Arrest
B. Impose Surcharges, Fines and Forfeitures
C. File Civil or Criminal Action
D. Impose Fine and Imprisonment
E. Compulsory Acquisition
F. Automatic Review by Secretary of Finance of Adverse Ruling
VI. Remedies of Importer
A. Payment under Protest
B. Appeal to Commissioner of Customs
C. Compromise
Week 14 FINALS

III. REFERENCES AND OTHER MATERIALS

Principal References: National Internal Revenue Code (Republic Act No. 8424)

Topical Required Readings/Assignments

Reference
RIGHTS AND REMEDIES OF THE GOVERNMENT
UNDER THE NATIONAL INTERNAL REVENUE CODE
I.A. Secs. 5 and 6, NIRC
II.A.1. Sec. 5(C), (D), NIRC
Sec. 6(C), NIRC
II.A.2. Sec. 5(B), (C), NIRC
II.B. Sec. 282, NIRC
BIR Rul. No. 071-00, Dec. 18, 2000
Meralco Securities Corp. v. Savellano, 117 SCRA 804 (1982)
Fitness by Design, Inc. v. CIR, G.R. No. 177982, Oct. 17, 2008
III.A. Sec. 6(A), NIRC
III.B. Sec. 6(B), NIRC
III.C. Sec. 6(C), NIRC
III.D. Sec. 6(D), NIRC
III.E. Sec. 6(E), NIRC
CIR v. Aquafresh Seafoods, Inc., G.R. No. 170389, Oct. 20, 2010
III.F. Sec. 228, NIRC
Sec. 3, Rev. Regs. No. 12-99, Sept. 6, 1999, as amended by Rev. Regs. No. 18-
2013, Nov. 28, 2013
III.G. Sec. 228, NIRC
Sec. 3, Rev. Regs. No. 12-99, Sept. 6, 1999
III.G.1. CIR v. Pascor Realty and Dev. Corp., 309 SCRA 402 (1999)
Fort Bonifacio Dev. Corp. v. CIR, CTA Case No. 5665, Aug. 11, 2000
Republic v. Court of Appeals, 149 SCRA 351 (1987)
III.G.2. Sy Po v. CTA, 164 SCRA 524 (1988)
III.G.3. CIR v. Benipayo, 4 SCRA 182 (1962)
Chemical Industries of the Phil., Inc. v. CIR, CTA Case No. 5257, Oct. 29,
1998
III.G.4. Sony Philippines, Inc. v. CIR, CTA Case No. 6185, Oct. 26, 2004
IV.A. Secs. 205-217, 224-225 NIRC
Sec. 202, NIRC
IV.B. Sec. 220, NIRC
Sec. 7(b)(2)(c), Rep. Act. No. 1125, as amended by Rep. Act. No. 9282
Sec. 11, Rep. Act. No. 1125, as amended by Rep. Act. No. 9282
Republic v. Lim Tian Teng Sons & Co., 16 SCRA 584 (1966)
San Juan v. Vasquez, 3 SCRA 92 (1961)
Yabes v. Flojo, L-46954, July 20, 1982
IV.C. Sec. 220, NIRC
Sec. 222(a), NIRC
Sec. 248(B), NIRC
Sec. 254, NIRC
Sec. 255, NIRC
Rev. Mem. Order No. 27-2010
CIR v. Pascor Realty and Dev. Corp., supra
Republic v. Patanao, 20 SCRA 712 (1967)
Ungab v. Cusi, G.R. No. L-41919-24, May 30, 1980
People v. Kintanar, CTA EB Crim No. 006, Dec. 3, 2010, aff. in G.R. No.
196340
IV.D.1. Sec. 218, NIRC
Churchill v. Rafferty, 32 Phil. 580 (1915)
CIR v. Cebu Portland Cement Co., 156 SCRA 535, 541 (1987)
IV.D.2 Sec. 11, Rep. Act. No. 1125, as amended by Rep. Act. No. 9282
Rule 10, Revised Rules of the CTA (S.C. A.M. No. 05-11-07-CTA, Nov. 22,
2005)
IV.E. Sec. 219, NIRC
IV.F. Sec. 204(A) and (B), NIRC
 BIR Rul. No. 111-99, July 22, 1999
BIR Rul. No. 059-01, Dec. 20, 2001
V.A. Sec. 248, NIRC
Secs. 250-252, NIRC
Secs. 4 & 5, Rev. Regs. No. 12-99, Sept. 6, 1999
CIR v. Javier, Jr., 199 SCRA 824, 831 (1991)
CIR v. Japan Air Lines, 202 SCRA 450, 458 (1991)
PICOP v. CIR, CTA Case No. 3215, Feb. 15, 1987
BIR Rul. No. 002-95, Jan. 6, 1995
BIR Rul. No. 048-99, April 13, 1999
BIR Rul. No. 205-99, Dec. 28, 1999
BIR Rul. No. 078-98, May 28, 1998
V.B. Sec. 249, NIRC
Sec. 5, Rev. Regs. No. 12-99, Sept. 6, 1999, as amended by Sec. 3, Rev. Regs.
18-2013, Nov. 28, 2013
Cagayan Electric v. CIR, 138 SCRA 629 (1985)
Republic v. Heras, 32 SCRA 507, 513-514 (1970)
V.C. Sec. 6, Rev. Regs. No. 12-99, Sept. 6, 1999
CIR v. Lianga Bay Logging Co., Inc., 193 SCRA 86, 92-93 (1991)
Atlas Consolidated Mining & Dev. Corp. v. CIR, CTA Case No. 5671, Aug.
29, 2002
RIGHTS AND REMEDIES OF TAXPAYER
UNDER THE NATIONAL INTERNAL REVENUE CODE
I. Sec. 6(A), NIRC, last paragraph
Rev. Mem. Cir. No. 40-2003, July 3, 2003
Rohm Apollo Semiconductor Phil. v. CIR, CTA E.B. No. 59 (CTA Case No.
6534, June 22, 2005)
II.A. Rev. Regs. No. 12-85, Nov. 27, 1985
Sec. 3, Rev. Regs. No. 12-99, Sept. 6, 1999, as amended by Sec. 2, Rev. Regs.
18-2013, Nov. 28, 2013
II.B. Sec. 228, NIRC
Pier 8 Arrastre and Stevedoring Services v. CIR, CTA Case No. 3789, Aug. 1,
1991
II.B.1. Sec. 228(a) to (e), NIRC
II.B.2 CIR v. Menguito, G.R. No. 167560, Sept. 17, 2008
CIR v. Metro Star Superama, G.R. No. 185371, Dec. 8, 2010
II.C. Sec. 228, NIRC
II.D. Sec. 228, NIRC
CIR v. Reyes, G.R. No. 159694, Jan. 27, 2006
Australasia Cylinder Corp. v. CIR, CTA Case No. 6014, Aug. 14, 2002
PNZ Marketing v. CIR, CTA Case No. 5726, Dec. 14, 2001
Phil. Mining Service Corp. v. CIR, CTA Case No. 5725, July 25, 2002
Oceanic Wireless Network v. CIR, CTA Case No. 6111, Nov. 3, 2004
CIR v. Subic Enron Power Corp., G.R. No. 166387, Jan. 19, 2009
II.E. Sec. 228, NIRC
II.E.1. Sec. 228, NIRC, 4th par.
II.E.2. H. Tambunting Pawnshop, Inc. v. CIR, CTA Case No. 6238, Oct. 8, 2004
CIR v. First Express Pawnshop Co., Inc., G.R. No. 172045-46, June 16, 2009
II.F. Sec. 228, NIRC
Dayrit v. Cruz, 165 SCRA 571 (1988)
III.A. Sec. 4, 2nd par., NIRC
Sec. 228, NIRC
Sec. 7, Rep. Act No. 1125, as amended by Rep. Act No. 9282
CIR v. Villa, 22 SCRA 4 (1968)
III.B. Sec. 3(a)(2), Rule 4 and Sec. 3(a), Rule 8, Revised Rules of the CTA (S.C.
A.M.
No. 05-11-07-CTA, Nov. 22, 2005)
Lascona Land Co., Inc. v. CIR, G.R. No. 171251, March 5, 2012
Rizal Commercial Banking Corp. v. CIR, G.R. No. 168498, April 24, 2007
III.C.2. Avon Products Mfg., Inc. v. CIR, CTA Case No. 5908, Jan. 20, 2005
III.C.3. CIR v. Isabela Cultural Corp., 361 SCRA 71 (2001)
III.C.4. CIR v. Ayala Securities Corp., 70 SCRA 204 (1976)
Surigao Electric Co. Inc. v. CTA, 57 SCRA 523 (1974)
III.C.5. CIR v. Union Shipping Corp., 185 SCRA 547 (1990)
III.C.6. Central Cement Corporation v. CIR, CTA Case No. 4312, Sept. 1, 1993
CIR v. Algue, Inc., 158 SCRA 9 (1988)
Advertising Associates, Inc. v. CA, 133 SCRA 765 (1984)
III.D. Sec. 228, last par., NIRC
Sec. 11, Rep. Act. No. 1125, as amended by Rep. Act. No. 9282
Basa v. Republic, 138 SCRA 34 (1985)
Mambulao Lumber Co. v. CIR, 132 SCRA 1 (1984)
III.E.1. Sec. 11, Rep. Act. No. 1125, as amended by Rep. Act. No. 9282
III.E.2. Sec. 18, Rep. Act. No. 1125, as amended by Rep. Act. No. 9282
IV. Sec. 19, Rep. Act. No. 1125, as amended by Rep. Act. No. 9282
V.A. CIR v. Central Azucarera Don Pedro, 49 SCRA 474 (1973)
V.B. Sec. 229, NIRC
Sec. 204(C), NIRC
Bermejo v. Collector, 87 Phil. 96 (1950)
Chemical Industries of the Phil., Inc. v. CIR, CTA Case No. 5887, Aug. 8,
2000
V.C. Sec. 229, NIRC, proviso, last paragraph
Sec. 204(C), NIRC
V.D. Sec. 229, NIRC
Manila Electric Co. v. CIR, CTA Case No. 7107, October 16, 2006
CIR v. Central Azucarera Don Pedro, supra
V.E. CIR v. Cebu Portland Cement Co., 156 SCRA 535, 541 (1987)
BPI Securities Corp. v. CIR, CTA Case No. 6089, Aug. 22, 2002
FNCB Finance v. CIR, CTA Case No. 3717, May 10, 1993
V.F. Philex Mining Corp. v. CIR, et. al., 306 SCRA 126 (1999)
V.G. Francia v. IAC, 162 SCRA 753 (1988)
BIR Ruling No. 415-93, Oct. 15, 1993
VI.A. Sec. 4, 2nd par., NIRC
Sec. 7(a)(1), (2), Rep. Act. No. 1125, as amended by Rep. Act. No. 9282
Sec. 11, Rep. Act. No. 1125, as amended by Rep. Act. No. 9282
Sec. 18, Rep. Act. No. 1125, as amended by Rep. Act. No. 9282
VI.B. Sec. 19, Rep. Act. No. 1125, as amended by Rep. Act. No. 9282
VII.A. Sec. 4, 1st par., NIRC
Revenue Administrative Order No. 3-2001, Oct. 22, 2001
VII.B.1. Sec. 4, 2nd par., NIRC
Sec. 7(a)(1), Rep. Act. No. 1125, as amended by Rep. Act. No. 9282
 Rodriguez v. Blaquera, 109 SCRA 598 (1960)
PNOC v. CA, 457 SCRA 52 (2005)
Phil. Journalists, Inc. v. CIR, 447 SCRA 214 (2004)
VII.B.2. CIR v. Leal, 392 SCRA 9 (2002)
Asia Int’l Auctioneers, Inc. v. Parayno, 540 SCRA 536 (2007)
British American Tobacco v. Camacho, 562 SCRA 571 (2008)
Sunlife of Canada v. CIR, CTA Case No. 7833, Jan. 12, 2009
Gorospe v. Vinzons-Chato, G.R. No. 132228, Jan. 21, 2003
Philamlife v. Sec. of Finance, G.R. No. 210987, Nov. 24, 2014
Banco de Oro v. RP, G.R. No. 198756, Jan. 13, 2015; read also Resolution on
Motions for Reconsideration, Aug. 16, 2016
Clark Investors and Locators Ass’n, Inc. v. Secretary of Finance, G.R. No.
200670, July 6, 2015
Commissioner of Internal Revenue v. Petron Corporation, G.R. 207842, July
15, 2015
VIII.A. Secs. 203, 222, 223 NIRC
VIII.A.1. Basilan Estates, Inc. v. CIR, 21 SCRA 17 (1967)
VIII.A.2. CIR v. Phoenix Assurance Co., Ltd., L-19127, May 20, 1965
VIII.A.3. Butuan Sawmill, Inc. v. CTA, L-20601, Feb. 28, 1966
VIII.A.4. CIR v. Primetown Prop. Group, Inc., G.R. No. 162155, August 28, 2007
VIII.A.5. Sec. 203, NIRC
VIII.A.6.a. Sec. 222(a), NIRC
Taligaman Lumber Co., Inc. v. CIR, 4 SCRA 842, 847 (1962)
Aznar v. CTA, 58 SCRA 519 (1974)
CIR v. BF Goodrich Phil., Inc., 303 SCRA 546 (1999)
Telesat, Inc. v. CIR, CTA Case No. 6812, Jan. 2, 2006
Estate of Reyes v. CIR, CTA Case No. 6747, Jan. 16, 2006
VIII.A.6.b. Sec. 222(b), NIRC
Republic v. Acebedo, 22 SCRA 1356 (1968)
CIR v. CA, et. al., 303 SCRA 614 (1999)
Philippine Journalists, Inc. v. CIR, 447 SCRA 214 (2004)
CIR v. Kudos Metal, Inc., G.R. No. 178087, May 5, 2010
CIR v. Next Mobile , Inc., G.R. No. 212825, Dec. 7, 2015
RCBC v. CIR, G.R. No. 170257, Sept. 7, 2011
VIII.A.6.c. Sec. 223, NIRC
Continental Micronesia, Inc. - Phil. Branch v. CIR, CTA Case No. 6191,
March 22, 2006
VIII.B. Secs. 203, 222, 223, NIRC
Republic v. Ablaza, 108 Phil. 1105 (1960)
Palanca v. CIR, 4 SCRA 263 (1962)
Republic v. Ker & Co. Ltd., 18 SCRA 208 (1966)
Republic v. Hizon, 320 SCRA 574 (1999)
CIR v. Wyeth Suaco Laboratories, Inc. and CTA, 202 SCRA 125, 131 (1991)
Bank of the Phil. Islands v. CIR, G.R. No. 139736, Oct. 17, 2005
CIR v. Hambrecht & Quist Phil., Inc., CTA E.B. No. 73 (CTA Case No.
6362), Aug. 12, 2005
VIII.C. Sec. 228, NIRC
VIII.D. See III(D) above
VIII.E. Sec. 204(C), NIRC
Sec. 229, NIRC
 Collector v. Sweeney, 109 Phil. 59 (1959)
Gibbs v. CIR, 107 Phil. 232 (1960)
CIR v. CA, et. al., 301 SCRA 435 (1999)
ACCRA Investments Corp. v. CA, G.R. No. 96322, Dec. 20, 1991
CIR v. TMX Sales, Inc., G.R. No. 83736, Jan. 15, 1992
VIII.E.1. CIR v. Primetown Prop. Group, Inc., supra
VIII.F. Sec. 281, NIRC
Lim v. CA, 190 SCRA 616 (1990)
IX Sec. 246, NIRC
CIR v. Burroughs Ltd., G.R. No. 66653, June 19, 1986
PBCom v. CIR, 302 SCRA 241 (1999)
ABS-CBN v. CTA, 108 SCRA 142 (1981)
ESTATE TAX
I. Rev. Regs. No. 02-2003, Dec. 16, 2002
I.A. Lorenzo v. Posadas, 64 Phil. 353 (1937)
Beam v. Yatco, 82 Phil. 30 (1948)
I.B. Secs. 85 and 104, NIRC
CIR v. Campos Rueda, 42 SCRA 23 (1971)
I.C.1. Sec. 85(A), NIRC
I.C.2. Sec. 85(B), NIRC
I.C.3. Sec. 85(B), NIRC
BIR Rul. No. 81-98, May 28, 1998
BIR Rul. No. 10-03, Sept. 8, 2003
I.C.4. Sec. 85(B), NIRC
I.C.5. Sec. 85(C), NIRC
BIR Rul. No. 013-2005, Aug. 16, 2005
BIR Rul. No. DA-279-2006, April 25, 2006
I.C.6. Sec. 85(D), NIRC
I.C.7. Sec. 85(E), NIRC
II. Secs. 85(G) and 88, NIRC
III. Sec. 87, NIRC
IV. Sec. 85(H), NIRC
V. Sec. 86, NIRC
V.A.3. Dizon v. Court of Tax Appeals, G.R. No. 140944, May 6, 2008
V.E. BIR Ruling 009-99, Jan. 22, 1999
VI. Sec. 86(E), NIRC
VII.B. Secs. 85 and 104, NIRC
VII.C. Sec. 86(B) and (D), NIRC
VII.D. Sec. 86(E), NIRC
VIII.A. Sec. 84, NIRC
VIII.B. Sec. 89, NIRC
VIII.C. Sec. 90, NIRC
VIII.D. Sec. 91, NIRC
VIII.E. Secs. 248, 249, 94 to 97, NIRC
DONOR’S TAX
I. Sec. 104, NIRC
CIR v. Duberstein, 363 U.S. 278 (1960)
Pirovano v. CIR, 14 SCRA 832 (1965)
II. Sec. 102, NIRC
III. Sec. 100, NIRC
Metro Pacific Corp. v. CIR, CTA Case No. 8318, June 11, 2014
Philamlife v. Sec. of Finance, G.R. No. 210987, Nov. 24, 2014
IV. Sec. 101, NIRC
V. Sec. 101(C), NIRC
VI. Sec. 98(A), NIRC
VII.A. Sec. 99, NIRC
VII.B. Sec. 103(A), NIRC
VII.C. Sec. 103(B), NIRC
VII.D. Sec. 248, NIRC
Sec. 249, NIRC
Sec. 95, NIRC
Sec. 97, NIRC
VALUE-ADDED TAX
I.A. Sec. 105, NIRC
BIR Rul. 98-97, Aug. 28, 1997
BIR Rul. No. 18-05, Sept. 16, 2005
VAT Rul. No. 444-88
VAT Rul. No. 207-90, Nov. 8, 1990
BIR Rul. No. 10-98, Feb. 5, 1998
CIR v. Commonwealth Mgt. & Services Corp., G.R. 125355, March 30, 2000
VAT Rul. No. 26-97, April 1, 1997
Tourist Trade and Travel Corp. v. CIR, CTA Case No. 4806, Jan. 19, 1996
BIR Rul. No. 113-98, July 23, 1998
Magsaysay Lines, Inc. v. CIR, G.R. No. 146984, July 28, 2006
Lapanday Foods Corp. v. CIR, CTA Case No. 7097, Oct. 18, 2007
I.B.1.a. Sec. 106(A)(1), NIRC, as amended by Rep. Act. No. 9337
I.B.1.b. Sec. 106(B), NIRC, as amended by Rep. Act No. 9337
Sec. 4.106-7, Rev. Regs. No. 16-2005, Sept. 1, 2005, as amended by Rev.
Regs. No. 4-2007, Feb. 7, 2007
I.B.1.c. Sec. 106(C), NIRC, as amended by Rep. Act. No. 9337
Sec. 4.106-8, Rev. Regs. No. 16-2005, Sept. 1, 2005, as amended by Rev.
Regs. No. 4-2007, Feb. 7, 2007
BIR Rul. No. 24-2005, Dec. 23, 2005
I.B.2.a. Sec. 106(A)(1), 2nd par., NIRC, as amended by Rep. Act No. 9337
Sec. 4.106-4, Rev. Regs. No. 16-2005, Sept. 1, 2005, as amended by Rev.
Regs. No. 4-2007, Feb. 7, 2007
I.B.2.b. Sec. 106(D), NIRC, as amended by Rep. Act No. 9337
Sec. 4.106-9, Rev. Regs. No. 16-2005, Sept. 1, 2005
VAT Ruling No. 204-90, Oct. 16, 1990
I.B.2.c. Sec. 4.106-7(b), Rev. Regs. No. 16-2005, Sept. 1, 2005, as amended by Rev.
Regs. No. 4-2007, Feb. 7, 2007
I.C. Sec. 107, NIRC, as amended by Rep. Act. No. 9337
I.D.1. Sec. 108(A), NIRC, as amended by Rep. Act. No. 9337
Sec. 4.108-2, Rev. Regs. No. 16-2005, Sept. 1, 2005
Lhuillier v. CIR, CTA Case No. 6533, May 16, 2003
I.D.2. Sec. 108(A), NIRC, as amended by Rep. Act. No. 9337
Sec. 4.108-4, Rev. Regs. No. 16-2005, Sept. 1, 2005, as amended by Rev.
Regs. No. 4-2007, Feb. 7, 2007
BIR Rul. No. 195-89, Sept. 8, 1989
 VAT Rul. No. 111-88, April 25, 1989
VAT Rul. No. 205-90, Oct. 16, 1990
I.D.2.a. Sec. 4.108-4, Rev. Regs. No. 16-2005, Sept. 1, 2005, as amended by Rev.
Regs. No. 4-2007, Feb. 7, 2007
CIR v. Tours Specialists, Inc., G.R. 66416, March 21, 1990
BIR Rul. No. DA-069-2006, March 1, 2006
I.D.2.b. Sec. 4.108-4, Rev. Regs. No. 16-2005, Sept. 1, 2005, as amended by Rev.
Regs. No. 4-2007, Feb. 7, 2007
VAT Rul. No. 283-88, July 4, 1988
VAT Rul. No. 87-88, April 14, 1988
VAT Rul. No. 97-88, April 15, 1988
II.A. Secs. 4.106-5, 1st par., and 4.108-5(a), Rev. Regs. No. 16-2005, Sept. 1, 2005
Cf. Sec. 4.109-1(A), Rev. Regs. No. 16-2005, Sept. 1, 2005
CIR v. Seagate Tech. (Phil.), G.R. 153866, Feb. 11, 2005
II.B.1. Sec. 106(A)(2)(a)(1), (2), (4) and (b), NIRC, as amended by Rep. Act. No.
9337
II.B.2. Sec. 108(B)(1), (2), (6) and (7), NIRC, as amended by Rep. Act. No. 9337
CIR v. American Express Int’l, Inc. (Phil.), G.R. 152609, June 29, 2005
CIR v. Burmeister & Wain Scandinavian Contractor Mindanao, Inc., G.R.
153205, Jan. 22, 2007
II.B.3. BIR Rul. No. 176-94
VAT Rul. No. 47-00, Oct. 26, 2000
II.C.1. Sec. 106(A)(2)(3), (5), (6) and (c), NIRC, as amended by Rep. Act No. 9337
Sec. 4.106-6, Rev. Regs. No. 16-2005, Sept. 1, 2005
II.C.2. Sec. 106(B)(3), (4) and (5), NIRC, as amended by Rep. Act No. 9337
Sec. 4.108-6, Rev. Regs. No. 16-2005, Sept. 1, 2005
II.D. Sec. 109(1), NIRC, as amended by Rep. Act. No. 9337
II.D.1.a. Philippine Acetylene Co., Inc. v. CIR, 20 SCRA 1056 (1967)
Phil. Nat’l Police Multi-Purpose Cooperative, Inc. v. CIR, CTA Case
No. 4845, March 10, 1994
BIR Rul. No. 155-98, Oct. 21, 1998
BIR Rul. No. 47-99, April 13, 1999
II.D.1.b. CIR v. John Gotamco & Sons, Inc., 148 SCRA 36 (1987)
Maceda v. Macaraig, Jr., 223 SCRA 217 (1993)
II.D.2. Sec. 109(2), NIRC, as amended by Rep. Act No. 9337
IV.A. Sec. 110, NIRC, as amended by Rep. Act. No. 9337, as further amended by
Rep. Act. No. 9361
Sec. 4.110-1, Rev. Regs. No. 16-2005, Sept. 1, 2005
IV.A.1. Sec. 110(A)(1)(b) and (A)(2), NIRC, as amended by Rep. Act. No. 9337
Sec. 4.110-2, Rev. Regs. No. 16-2005, Sept. 1, 2005
IV.A.2. Sec. 110(A), proviso, NIRC, as amended by Rep. Act. No. 9337
Sec. 4.110-3, Rev. Regs. No. 16-2005, Sept. 1, 2005, as amended by Rev.
Regs. No. 4-2007, Feb. 7, 2007
IV.A.3. Sec. 110(A)(3), NIRC, as amended by Rep. Act. No. 9337
Sec. 4.110-4, Rev. Regs. No. 16-2005, Sept. 1, 2005, as amended by Rev.
Regs. No. 4-2007, Feb. 7, 2007
IV.A.4. Sec. 4.110-8, Rev. Regs. No. 16-2005, Sept. 1, 2005
BIR Rul. No. 61-00, Nov. 8, 2000
IV.B. Sec. 111(A), NIRC, as amended by Rep. Act. No. 9337
Sec. Sec. 4.111-1(a), Rev. Regs. No. 16-2005, Sept. 1, 2005
IV.C. Sec. 111(B), NIRC, as amended by Rep. Act. No. 9337
Sec. Sec. 4.111-1(b), Rev. Regs. No. 16-2005, Sept. 1, 2005
IV.D. Sec. 114(C), NIRC, as amended by Rep. Act. No. 9337
Sec. Sec. 4.114-2(a), Rev. Regs. No. 16-2005, Sept. 1, 2005, as amended by
Rev. Regs. No. 4-2007, Feb. 7, 2007
See Illustration in Sec. Sec. 4.110-4, Rev. Regs. No. 16-2005, Sept. 1, 2005, as
amended by Rev. Regs. No. 4-2007, Feb. 7, 2007
IV.E. Sec. 112, NIRC, as amended by Rep. Act. No. 9337
IV.E.1. Sec. 112(A), NIRC, as amended by Rep. Act. No. 9337
IV.E.2. Sec. 112(B), NIRC, as amended by Rep. Act. No. 9337
IV.E.3. Sec. 112(C), NIRC, as amended by Rep. Act. No. 9337
Correlate with Sec. 229, NIRC
CIR v. Mirant Pagbilao Corp., G.R. No. 172129, Sept. 12, 2008
CIR v. San Roque Power Corp., G.R. No. 187485, Feb. 12, 2013
Rev. Mem. Circular No. 54-2014, June 11, 2014
Rohm Apollo Semiconductor Phil., G.R. No. 168950, Jan. 14, 2015
Clark Investors and Locators Ass’n v. Secretary of Finance, G.R. No. 200670,
July 6, 2015
V.A. Sec. 236, NIRC, as amended by Rep. Act No. 9337
V.A.1. Sec. 236(G), NIRC, as amended by Rep. Act No. 9337
Sec. Sec. 9.236-1(b), Rev. Regs. No. 16-2005, Sept. 1, 2005
V.A.2. Sec. 236(H), NIRC, as amended by Rep. Act No. 9337
Sec. Sec. 9.236-1(c), Rev. Regs. No. 16-2005, Sept. 1, 2005
V.A.3. Sec. 236(G)(2), NIRC, as amended by Rep. Act No. 9337
V.A.4. Sec. 236(F), NIRC, as amended by Rep. Act No. 9337
Sec. Sec. 9.236-6, Rev. Regs. No. 16-2005, Sept. 1, 2005
V.B. Sec. 113(C), NIRC, as amended by Rep. Act No. 9337
Sec. Sec. 4.113-3, Rev. Regs. No. 16-2005, Sept. 1, 2005
V.C. Sec. 113, NIRC, as amended by Rep. Act No. 9337
V.C.1. Sec. 113(A) and (B), NIRC, as amended by Rep. Act No. 9337
Sec. Sec. 4.113-1(A) and (B), Rev. Regs. No. 16-2005, Sept. 1, 2005
V.C.2. Sec. 4.113-2, Rev. Regs. No. 16-2005, Sept. 1, 2005
V.C.3. Sec. 113(D), NIRC, as amended by Rep. Act No. 9337
Sec. 4.113-4, Rev. Regs. No. 16-2005, Sept. 1, 2005
V.D. Sec. 4.114-2(b), Rev. Regs. No. 16-2005, Sept. 1, 2005
VI. Sec. 114, NIRC, as amended by Rep. Act No. 9337
Sec. Sec. 4.114-1(A), Rev. Regs. No. 16-2005, Sept. 1, 2005
OTHER PERCENTAGE TAXES
I.A. Sec. 116, NIRC, as amended by Rep. Act No. 9337
I.B. Sec. 117, NIRC, as amended by Rep. Act No. 9337
I.C. Sec. 118, NIRC
I.D. Sec. 119, NIRC, as amended by Rep. Act No. 9337
I.E. Sec. 120, NIRC
I.F. Sec. 121, NIRC, as amended by Rep. Act No. 9337
CIR v. Solidbank Corp., G.R. No. 148191, Nov. 5, 2003
I.G. Sec. 122, NIRC
I.H. Sec. 123, NIRC
I.I. Sec. 124, NIRC
I.J. Sec. 125, NIRC
I.K. Sec. 126, NIRC
I.L. Sec. 127, NIRC
II. Sec. 128, NIRC
EXCISE TAX
I.A. Sec. 129, NIRC
I.B. Secs. 141 – 143, NIRC, as amended by Rep. Act No. 9334
I.C. Secs. 144 – 145, NIRC, as amended by Rep. Act No. 9334
Secs. 146 – 147, NIRC
I.D. Sec. 148, NIRC, as amended by Rep. Act No. 9337
I.E.1. Sec. 149, as amended by Rep. Act No. 9224
I.E.2. Sec. 150, NIRC
I.F. Sec. 151, NIRC, as amended by Rep. Act No. 9337
II. Sec. 130, NIRC
Sec. 131, NIRC, as amended by Rep. Act No. 9334
Secs. 132 – 140, NIRC
III. Sec. 130(C), NIRC
Secs. 152 – 172, NIRC
DOCUMENTARY STAMP TAX
I. Sec. 173, NIRC
CIR v. Heald Lumber, 10 SCRA 372
Michel J. Lhuillier Pawnshop, Inc. v. CIR, G.R. No. 166786, May 3, 2006
II.A. Sec. 174, NIRC, as amended by Rep. Act No. 9243
II.B. Sec. 175, NIRC, as amended by Rep. Act No. 9243
Compagnie Financiere Sucres et Deneres v. CIR, G.R. No. 133834, Aug. 28,
2006
II.C. Sec. 176, NIRC
II.D. Sec. 177, NIRC
II.E. Sec. 178, NIRC
II.F. Sec. 179, NIRC, as amended by Rep. Act No. 9243
Banco de Oro Universal Bank v. CIR, CTA Case No. 6568, Aug. 5, 2005
Belle Corp. v. CIR, CTA Case No. 6156, June 17, 2005
II.G. Sec. 180, NIRC, as amended by Rep. Act No. 9243
II.H. Sec. 181, NIRC
II.I. Sec. 182, NIRC
II.J. Sec. 183, NIRC, as amended by Rep. Act No. 9243
BIR Rul. No. DA-182-2005, April 20, 2005
II.K. Sec. 184, NIRC
BIR Rul. No. DA-288-2005, June 27, 2005
II.L. Sec. 185, NIRC
II.M. Sec. 186, NIRC, as amended by Rep. Act No. 9243
II.N. Sec. 187, NIRC
II.O. Sec. 188, NIRC
II.P. Sec. 189, NIRC
II.Q. Sec. 190, NIRC
II.R. Sec. 191, NIRC
II.S. Sec. 192, NIRC
II.T. Sec. 193, NIRC
II.U. Sec. 194, NIRC
II.V. Sec. 195, NIRC
II.W. Sec. 196, NIRC
BIR Rul. No. DA-076-2005
BIR Rul. No. DA-084-2005, March 14, 2005
BIR Rul. No. DA-065-2005, Feb. 23, 2005
BIR Rul. No. DA-640-2004, Dec. 17, 2004
BIR Rul. No. DA-648-2004, Dec. 21, 2004
II.X. Sec. 197, NIRC
II.Y Sec. 198, NIRC
III. Sec. 199, NIRC, as amended by Rep. Act No. 9243
BIR Rul. No. DA-244-2005, June 7, 2005
Belle Corp. v. CIR, CTA Case No. 6156, June 17, 2005
IV. Sec. 200, NIRC
V. Sec. 201, NIRC
LOCAL TAXATION
I.A. Sec. 129, Local Government Code of 1991 (“LGC”)
Mactan Cebu Int’l Airport Authority v. Marcos, G.R. No. 120082, Sept. 11,
1996
Manila Electric Co. v. Prov. of Laguna, G.R. No. 131359, May 5, 1999
I.B. Sec. 130, LGC
Pepsi Cola Bottling Co. of the Phils., Inc. v. Mun. of Tanauan, L-31156, Feb.
27, 1976
Ormoc Sugar Co., Inc. v. Mun. Board of Ormoc City, L-24322, July 21, 1967
Asiatic Integrated Corporation v. Alikpala, 72 SCRA 285
Matalin Coconut Co. v. Mun. Council of Malabang, 143 SCRA 404
I.C. Sec. 133, LGC
Prov. of Bulacan v. CA, G.R. No. 126232, Nov. 27, 1998
Phil. Petroleum Corp. v. Mun. of Pililla, G.R. No. 90776 June 3, 1991
San Miguel Corp. v. Mun. Council of Mandaue, L-30761, July 11, 1973
II.A. Secs. 135-141, LGC
II.B. Secs 142-143, LGC
II.C. Sec. 151, LGC
Art. 237, IRR
II.D. Sec. 152, LGC
III.A. Secs. 157-159, LGC
Art. 246, IRR
III.B. Sec. 159, LGC
III.C. Secs. 160-161, LGC
IV.A.1. Secs. 165-167, LGC
IV.A.2. Sec. 166, LGC
IV.A.3. Sec. 145, LGC
Art. 241, IRR
IV.B. Sec. 146, LGC
Art. 242, IRR
Standard Vacuum Oil Co. v. Antigua, 96 Phil. 909
Ali Nam v. City of Manila, 109 Phil. 808
IV.C.1. Sec. 150(a), LGC
Art. 243, IRR
IV.C.2. Sec. 150(b) to (e), LGC
Art. 243, IRR
IV.C.3. Art. 243(d), IRR
V.A. Sec. 186, last proviso, LGC
Sec. 187, LGC
Art. 275, IRR
Figueras v. CA, G.R. No. 119172, March 25, 1999
Tuzon v. CA, 212 SCRA 739, 745 (1992)
V.B. Sec. 188, LGC
Art. 276, IRR
Figueras v. CA, et. al., supra
V.C. Sec. 187, LGC
Reyes, et. al. v. CA, G.R. No. 118233, Dec. 10, 1999
Drilon v. Lim, G.R. No. 112497, Aug. 4, 1994
Hagonoy Market Vendor Assoc. v. Mun. of Hagonoy, Bulacan, 376 SCRA
376
V.D. Id.
V.E. Id.
VI.A.1. Sec. 171, LGC
VI.A.2. Sec. 195, LGC
Sec. 194, LGC
VI.A.3 Secs. 168-169, LGC
VI.A.4.a. Sec. 175, LGC
VI.A.4.b. Secs. 176, 178-182, LGC
VI.A.4.c. Sec. 184, LGC
VI.A.5. Sec. 183, LGC
VI.B.1. Sec. 195, LGC
Art. 285, IRR
California Mfg. Co., Inc. v. City of Las Piñas, CTA AC No. 4, Sept. 28, 2005
VI.B.2. Sec. 196, LGC
Art. 286, IRR
VII. Sec. 192, LGC and Art. 282, IRR
See also Sec. 193, LGC and Art. 283, IRR re. withdrawal of existing tax
exemption privileges
REAL PROPERTY TAXATION
I. Sec. 198, LGC
Sec. 199, LGC
Reyes v. Almanzor, 196 SCRA 322 (1991)
Meralco v. Central Board of Assessment Appeals (CBAA), 114 SCRA 260
(1982)
Caltex Phils. Inc. v. CBAA, 114 SCRA 296
Benguet Corp. v. CBAA, 218 SCRA 271 (1993)
Prov. of Nueva Ecija v. Imperial Mining Co., Inc., 118 SCRA 632 (1982)
Ty v. Trampe, 250 SCRA 500 (1995)
Lopez v. City of Manila, 303 SCRA 448 (1999)
II.A. Sec. 233, LGC
Lopez v. City of Manila, supra
II.B. Sec. 235, LGC
II.C. Secs. 236-237, LGC
II.D. Secs. 240-243, LGC
III. Sec. 234, LGC
Light Rail Transit Authority v. CBAA, 342 SCRA 692 (2000)
IV.A. Sec. 246, LGC
 Sec. 245, LGC
IV.B. Sec. 250, LGC
IV.C. Sec. 251, LGC
V.A. Sec. 201, LGC (Real Property)
Secs. 224-225, LGC (Machineries)
V.A.1. Secs. 202-203, LGC
See also Sec. 208, LGC
V.A.2. Sec. 204, LGC
See also Sec. 213, LGC
Allied Banking Corp. v. QC Gov’t, 472 SCRA 303 (2005)
V.B.1. Sec. 217, LGC
Secs. 215-216, LGC
V.B.2. Sec. 218, LGC
V.B.3. Sec. 219, LGC
Art. 310, IRR
Lopez v. City of Manila, supra
V.B.4 Sec. 220, LGC
Sec. 221, LGC
Callanta v. Office of the Ombudsman, 285 SCRA 648 (1998)
Meralco v. Barlis, 375 SCRA 570 (2002)
VI.A. Sec. 254, LGC
VI.B. Sec. 255, LGC
VI.C. Secs. 256-257, LGC
Secs. 258-265, LGC
VI.D. Sec. 256, LGC
Sec. 266, LGC
Sec. 270, LGC
VI.E. Sec. 257, LGC
VII.A.1. Sec. 226, LGC
Callanta, et. al. v. Office of the Ombudsman, supra
VII.A.2. Sec. 229(c), LGC
VII.A.3. Sec. 7, Rep. Act No. 1125, as amended by Rep. Act No. 9282
VII.A.4. Sec. 231, LGC
VII.B. Sec. 252, LGC
Art. 343, IRR
Camp John Hay Dev’t Corp. v. CBAA, CTA E.B. No. 48 (CBAA Case No.
L- 37; Tax Appeal Case No. 2002-2003 Board of Tax Assessment Appeals,
Baguio City), July 27, 2005
National Power Corp. v. Prov. of Quezon and Mun. of Pagbilao, CTA E.B.
No. 46 (CBAA Case No. L-29)
City of Lapu-Lapu v. PEZA, 742 SCRA __ (2014)
VII.C. Sec. 253, LGC
China Banking Corp. v. City Treasurer of Kalookan, CTA Case AC No. 12,
Aug. 31, 2005
TARIFF AND CUSTOMS CODE
I.A. Sec. 103, TCCP
I.B. Sec. 104, TCCP
Sec. 204, TCCP
I.C. Sec. 203, TCCP
I.D. Sec. 100, TCCP
I.E. Sec. 105, TCCP
I.F. Sec. 101, TCCP
I.G. Sec. 106, TCCP
II.A. Sec. 201, TCCP
II.B. Sec. 202, TCCP
III.A. Sec. 301, TCCP
III.B. Sec. 302, TCCP
III.C. Sec. 303, TCCP
III.D. Sec. 304, TCCP
IV.A. Sec. 1202, TCCP
IV.B. Sec. 1203, TCCP
IV.C. Sec. 1204, TCCP
V.A. Secs. 2202-2212, TCCP
Secs. 2301-2306, TCCP
V.B. Sec. 2307, TCCP
Secs. 2501-2536, TCCP
V.C. Sec. 2401, TCCP
V.D. Secs. 3601-3612, TCCP
V.E. Sec. 2317, TCCP
V.F. Sec. 2313, TCCP
VI.A. Secs. 2308-2312, TCCP
VI.B. Sec. 2313, TCCP
VI.C. Sec. 2316, TCCP
*All readings are required, supplemental readings shall be assigned during the semester as needed.
The professor reserves the option of amending the reading list and assignments as exigencies
warrant.

IV. COURSE REQUIREMENTS AND GRADING SYSTEM

Course Grade Breakdown Description

Requirements
Recitations 35% Assess the understanding of students of
jurisprudence, law and other readings
Midterms 30% Written examination to evaluate the
competence in applying jurisprudence and laws
on a given set of facts
Finals 35% Written examination to evaluate the
competence in applying jurisprudence and laws
on a given set of facts

V. COURSE POLICIES

Please see the Rules and Regulations on attendance, dress code, discipline, J.D. scholastic
responsibility, and plagiarism, in the ALS Catalogue. In addition, all written paper
requirements should first pass through the plagiarism checker, available at the APS Library,
prior to submission.

VI. CONTACT AND OTHER INFORMATION

Atty. Terence Conrad H. Bello
Baniqued & Baniqued
633-9418 (Office); 633-1911 (Fax)
thbello@baniquedlaw.com
www.baniquedlaw.com