Request for the Reinvestigation of Income Tax Deficiency

September 30, 1959 BIR RULING NO. 496-59 Atty. Artemio M. Lobrin Suites 314-315 Yuchengco Bldg. 484 Rosario, Manila Re: Dee Hong Lue & Sons S i r : The written waiver of the Statute of Limitations having been submitted to this Office, duly executed by your client, your request for the reinvestigation of the latter's deficiency income tax case for the year 1956, is hereby granted. However, with respect to your request for the reconsideration of our decision denying your previous request for the lifting of the preventive embargo on the three trucks of your client, we regret to inform you that your request cannot be granted. Republic Act No. 2343 which amended section 51(d) of the Tax Code has made sections 331 and 332 of the same Code applicable to income tax. The amendment, being procedural or remedial in character, can be given a retroactive effect. (Commissioner of Internal Revenue vs. Anna Harriet Clement, et al., G. R. No. L-12194, January 24, 1959) Very truly yours, (SGD.) MELECIO R. DOMINGO Commissioner of Internal Revenue