Commissioner of Internal Revenue v. Asia United Leasing & Finance Corp.
C.T.A. EB Case No. 2390 (C.T.A. Case No. 8735) (Resolution) • Court of Tax Appeals • Decisions • Mar 10, 2021
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EN BANC [C.T.A. EB CASE NO. 2390. March 10, 2021.] (C.T.A. Case No. 8735) COMMISSIONER OF INTERNAL REVENUE , petitioner , vs. ASIA UNITED LEASING & FINANCE CORPORATION , respondent . RESOLUTION For the Court's resolution is petitioner's "Motion for Reconsideration (Re: Resolution dated 12 January 2021)" ("Motion"), filed on 19 February 2021. In his Motion, petitioner claims to have received the assailed Resolution on 4 February 2021, giving him until 19 February 2021 within which to file a Motion for Reconsideration. A perusal of the records would show, however, that petitioner received said Resolution on 3 February 2021, giving him until 18 February 2021 within which to file a Motion for Reconsideration. As he filed the instant Motion on 19 February 2021, the same is filed out of time. aDSIHc WHEREFORE , the instant Motion for Reconsideration is hereby DENIED for being filed out of time. SO ORDERED. 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. Roman G. del Rosario, P.J. , is on leave.
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