BIR Ruling [DA-284-99]

May 13, 1999 BIR RULING [DA-284-99] Philippine Deposit Insurance Corporation 2228 Pasong Tamo Street Makati City Attention: Ms . Ma . Bernadette R . Sanchez Deputy Liquidator Pacific Banking Corp. Gentlemen : This refers to your letter dated June 1, 1998 stating that Pacific Banking Corporation is a closed banking institution presently under liquidation pursuant to Monetary Board Resolution No. 1233 dated November 22, 1985; and that the President of the Philippine Deposit Insurance Corporation was duly designated as its Liquidator pursuant to Monetary Board Resolution No. 537 dated May 17, 1991. Based on the foregoing, you now request for copies of the Income Tax Return of Pacific Banking Corporation from 1986 to 1991 relative to the bank's documentation/evaluation of BIR's claim of P213,239,661.65 representing deficiency income tax covering the said years. Please be informed that your request is hereby granted inasmuch as the same does not violate Section 270 of the Tax Code of 1997. This will therefore, serve as an authority for the Assistant Commissioner, Information Systems and Operation Service to furnish you or your duly authorized representative with the aforementioned document upon presentation of your or your authorized representative's identification card/paper and the original copy of the Monetary Board Resolution No. 537, dated May 17, 1991 designating you as the liquidator of Pacific Banking Corporation. This ruling is being issued on the basis of the foregoing facts as represented. However, if upon investigation, it will be disclosed that the facts are different, then this ruling shall be considered null and void. Very truly yours, (SGD.) SIXTO S. ESQUIVIAS IV Deputy Commissioner (Legal and Enforcement Group)