Loadstar International Shipping, Inc. v. Commissioner of Internal Revenue

EN BANC [C.T.A. EB CASE NO. 2011. July 7, 2021.] (C.T.A. Case No. 9176) LOADSTAR INTERNATIONAL SHIPPING, INC. , petitioner , vs. COMMISSIONER OF INTERNAL REVENUE , respondent . RESOLUTION In the Resolution dated 08 March 2021, the Court ordered respondent to file his comment to petitioner's "Motion for Reconsideration [Re: Decision dated November 11, 2020]" within five (5) calendar days from receipt hereof. Respondent filed his "Opposition (re: Petitioner's Motion for Reconsideration dated 26 November 2020)" (opposition) via email on 22 March 2021. However, he submitted eleven (11) hard copies of the said opposition only on 08 June 2021. Pursuant to CTA En Banc Resolution No. 4-2021 dated 24 February 2021, litigants shall submit, by personal filing or licensed courier, the required number of hard copies of the pleadings, motions, and other court submissions within five (5) calendar days from date of filing by email. 1 Failure to do so shall be a ground for declaring the pleading, motion, and other court submission as deemed not filed which may result in the dismissal of the petition for review, complaint or information, and the imposition of other appropriate sanctions as may be determined by the Court. 2 TCAScE In view of the foregoing En Banc Resolution and considering the lapse of time between the filing of respondent's opposition via email and the filing of the hard copies on 08 June 2021, the Court is constrained to treat respondent's "Opposition (re: Petitioner's Motion for Reconsideration dated 26 November 2020) as DEEMED NOT FILED . WHEREFORE , petitioner's "Motion for Reconsideration [Re: Decision dated November 11, 2020]" is now SUBMITTED for resolution. SO ORDERED. Roman G. del Rosario, P.J., Juanito C. Castaeda, Jr., Erlinda P. Uy, Ma. Belen M. Ringpis-Liban, Catherine T. Manahan, Jean Marie A. Bacorro-Villena and Maria Rowena Modesto-San Pedro, JJ. , concur. Footnotes 1. Paragraph 3. 2. Paragraph 6.