On June 21, 1989, the petitioner received an assessment letter from the Commissioner of Internal Revenue for the payment of deficiency amusement tax amounted to P5,864,260.84.
Petitioner contested the assessment by filing a protest who denied the same by the Commissioner of Internal Revenue.
On January 8, 1990, petitioner filed a petition for review with the Court of Tax Appeals whom on December 24, 1993, dismissed petitioner’s petition, holding petitioner to pay P5,864,260.84 as deficiency amusement tax for the year 1987 plus 20% annual delinquency interest from July 22, 1989 pursuant to the provision of Sec.248 & 249
Petitioner presented a motion for reconsideration of the said decision but the same was denied by CTA. Petitioner appealed the CTA decision to the Court of Appeals, however, the CA affirmed CTA’s decision.