CIR v. Dunlevy Food Corporation


CIR v. Dunlevy Food Corporation

CTA EB NO. 2294

July 18, 2022


The Court En Banc has jurisdiction over the petitioner Commissioner of Internal Revenue’s Motion for Reconsideration.


Whether or not the motion for reconsideration should be granted.


No. After careful evaluation of the arguments raised by petitioner vis-a-vis the

records of the case, the Court En Bane resolves to deny petitioner's Motion for

Reconsideration [En Bane Dedsion dated 08 February 2022] for lack of merit. Petitioner failed to raise any new or substantial matter let alone any compelling reason to warrant the modification much less reversal of this Court's findings.

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