Cited Laws
TL;DR — Ruling
WHEREFORE , premises considered, the instant Petition for Review is hereby GRANTED . Accordingly, [the Commissioner of Internal Revenue] is ordered to REFUND [,] or in the alternative, ISSUE A TAX CREDIT CERTIFICATE in favor of [the Estate of Mr. Charles Marvin Romig, represented by its sole heir, Mrs. Maricel Narciso Romig] in the amount of [PHP] 4,565,349.
WHEREFORE , premises considered, the instant Petition for Review is hereby GRANTED . Accordingly, [the Commissioner of Internal Revenue] is ordered to REFUND [,] or in the alternative, ISSUE A TAX CREDIT CERTIFICATE in favor of [the Estate of Mr. Charles Marvin Romig, represented by its sole heir, Mrs. Maricel Narciso Romig] in the amount of [PHP] 4,565,349.07, representing erroneously paid estate tax, including interest and penalties, on petitioner's foreign currency deposit with HSBC. SO ORDERED.