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CIR v. Villa

The spouses Villa filed a petition for review with the Court of Tax Appeals (CTA) appealing tax deficiency assessments issued by the Bureau of Internal Revenue (BIR) for the years 1951 to 1956 without first contesting the assessments with the Commissioner of Internal Revenue (CIR). The CIR appealed to the Supreme Court questioning the jurisdiction of the CTA. The Supreme Court ruled that the CTA did not have jurisdiction over the case because the taxpayers did not first dispute the assessments with the CIR before appealing, making the appeal to the CTA premature. The CTA can only review decisions made by the CIR on disputed assessments.

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139 views1 page

CIR v. Villa

The spouses Villa filed a petition for review with the Court of Tax Appeals (CTA) appealing tax deficiency assessments issued by the Bureau of Internal Revenue (BIR) for the years 1951 to 1956 without first contesting the assessments with the Commissioner of Internal Revenue (CIR). The CIR appealed to the Supreme Court questioning the jurisdiction of the CTA. The Supreme Court ruled that the CTA did not have jurisdiction over the case because the taxpayers did not first dispute the assessments with the CIR before appealing, making the appeal to the CTA premature. The CTA can only review decisions made by the CIR on disputed assessments.

Uploaded by

Ridzanna Abdulgafur
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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64. CIR v.

Villa, 22 SCRA 4 (1968)

Facts:

The spouses Villa filed joint income tax returns for the years 1951 to 1956. The BIR issued assessments for
deficiency of income tax for the said years. Without contesting the said assessments with the CIR, they filed a
petition for review with the CTA. The CTA took cognizance of the of the appeal and rendered favorable
judgment to the spouses. The CIR appealed to the SC questioning the jurisdiction of the CTA.

Issue:

Whether or not the CTA has jurisdiction.

Ruling:

No. Since jurisdiction is conferred by law, it can take cognizance only of such matters as are clearly within its
jurisdiction. Where a taxpayer questions an assessment and asks the Collector to reconsider or cancel the
same because he (the taxpayer) believes he is not liable therefor, the assessment becomes a "disputed
assessment" that the Collector must decide, and the taxpayer can appeal to the Court of Tax Appeals only
upon receipt of the decision of the Collector on the disputed assessment. Since in the instant case the
taxpayer appealed the assessment of the Commissioner of Internal Revenue without previously contesting the
same, the appeal was premature and the Court of Tax Appeals had no jurisdiction to entertain said appeal.
For, as stated, the jurisdiction of the Tax Court is to review by appeal decisions of Internal Revenue on
disputed assessments.

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