Suyoc Doctrine
BIR Ruling No. 089-60 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Feb 11, 1960
Full text
February 11, 1960 BIR RULING NO. 089-60 2nd Indorsement Returned to the Regional Director, BIR Regional District No. 4, Quezon City, the entire docket bearing on the case of Mrs. Patrocinia B. Santos. A restudy of the case showed that the request for reinvestigation was granted in writing by this office. The petition of the taxpayer for reconsideration was equally made in writing. Under the circumstances, the taxpayer, under the doctrine of the Suyoc case, is now estopped to raise the defense of prescription. She is advised to be guided accordingly. LLjur MELECIO R. DOMINGO Commissioner of Internal Revenue
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