UPSI Management, Inc. v. Commissioner of Internal Revenue

THIRD DIVISION

[G.R. No. 199649. March 14, 2012.]

NOTICE

Sirs/Mesdames :

Please take notice that the Court, Third Division, issued a Resolution dated 14 March 2012, which reads as follows:

G.R. No. 199649(UPSI Management, Inc. v. Commissioner of Internal Revenue).

RESOLUTION

After a review of the records, the Court resolves to DENY the petition for failure to show that the Court of Tax Appeals En Banc committed any reversible error when it affirmed its First Division's Decision dated April 15, 2010 and its Resolution dated August 10, 2010 as to warrant the exercise by the Court of its discretionary appellate jurisdiction.

It is an established doctrine that findings of fact of the Court of Tax Appeals are conclusive on the Court and will not be reviewed or disturbed on appeal.

The unanimous finding of the Court of Tax Appeals Division and En Banc that petitioner UPSI Management, Inc. carried over its 2005 claimed unutilized tax credit to the first three quarters of 2006 is persuasive on the Court.

SO ORDERED.

Very truly yours,

(SGD.) LUCITA ABJELINA-SORIANODivision Clerk of Court