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L-8685
THE
COLLECTOR
OF
INTERNAL
REVENUE, petitioner,
vs.
AURELIO P. REYES and COURT OF TAX
APPEALS, respondents.
FELIX, J.:
Nature:
This is a petition for certiorari filed by P wherein he
seeks to nullify the resolution of the CTA Appeals
restraining him from collecting, through summary
administrative methods, taxes allegedly due from Dr.
Aurelio P. Reyes.
Facts:
On October 13, 1954, P, demanded from R payment of
his alleged deficiency in his income taxes, surcharges,
interests and penalties for the tax years 1946 to 1950
amounting to P641,470.04 as of October 31, 1954, with
the suggestion that the aforesaid tax liabilities be paid
either to the Bureau of Internal Revenue or the City
Treasurer of Manila. Together with said letter of
assessment R received a warrant of distraint and levy on
his properties in the event that he should fail to pay the
alleged deficiency on or before October 31, 1954.
On November 4, 1954, R was informed that the City
Treasurer was instructed by P to execute the warrant of
distraint and levy on the properties, if the amount
demanded is not settled on or before November 10,
1954.
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