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Republic Act No.

1125 June 16, 1954 restrictions and qualifications as apply in judicial proceed
have the power to punish for contempt for the same caus
AN ACT CREATING THE COURT OF TAX APPEALS
Section 11. Who may appeal; effect of appeal. - An
Section 1. Court; Judges; qualifications; salary; tenureInternal Revenue, the Collector of Customs or any provinc
two Associate Judges, each of whom shall be appointed by the days after the
President, receipt
with of such decision
the consent or ruling. on Appo
of the Commission
so designated in the commission issued to him by the President, and the Associate Judges shall have precedence acco
The Presiding Judge shall receive a compensation of thirteen No appeal
thousandtaken
pesos
by theperCourt
annumof Appeals
and shall
fromhave
the the
decisio
sam
privileges as the Presiding Judge of the Court of Industrial Relations.
distraint,The
andAssociate
or sale ofJudges
any property
shall each
of the
receive
taxpayer
a compe
for t
annum and shall have the same qualifications, rank, category opinion
and privileges
of the Court
as athe
member
collection
of the
by the
CourtBureau
of Industrial
of InternR
Associate Judges shall be appointed to hold office during goodthe taxpayer
behavior,theuntil
Court
theyatreach
any stage
the age
of the
of proceeding
seventy, or mabe
duties of their office, unless sooner removed for the same causes
file a and
surety
in the
bondsame
for not
manner
moreprovided
than double
by law
thefor
amount
membe w

Section 2. Quorum; temporary vacancy. - Any two Judges Section


of the Court
12. Taking
of Tax Appeals
of evidence.
shall constitute
- The Courta quorum,
may, upon a
be necessary to promulgate any decision thereof. In case of temporary
members forvacancy,
the taking
disability
of evidence,
or disqualification,
when the determina
for any r
Court, the President may, upon the request of the Presiding Judge,
the taking
designate
of an account
any Judge
is of
necessary,
First Instance
or when
to act
theindeter
his p
shall be duly qualified to act as such. member shall proceed in all respects as though the same

Section 3. Clerk of court; appointment; qualification; compensation


Upon the recommendation of such hearing such member
by the President with the consent of the Commission on Appointments.
and thereafter,No person
the Courtshallshall
be appointed
render its Clerk
decisions
of Court
on theu
law in the Philippines. The Clerk of Court shall exercise the same
Courtpowers
may, inandits perform
discretion therecommit
same duties
it within instructions,
regard to all
as are exercise and performed by clerks of Court of First Instance, in so far of those powers and the performance of th
direction of the said court. The Clerk of Court shall receive a compensation of six thousand
Section 13. Decision. - Cases pesos per before
brought annum.the Court
shall be in writing, stating clearly and distinctly the facts
Section 4. Other subordinate employees. - The Court ofprovide Tax Appeals
for theshall
publication
appoint,ofinitsaccordance
decisions in with
thethe
Official
Civil GS
necessary personnel to assist it in the performance of its duties. The said Court shall fix their salaries and prescribe the
As in the case of judicial officers under section one hun
Section 5. Disqualifications. - No judge or other officer orapplications
employee of for theleave,
Court ofandTaxupon
Appeals
salary
shallvouchers
intervene, prese
dir
or control of any private enterprise which in any way may beproceedings,
affected by the petitions
functionsandofmotions
the Court.
whichJudges
have of been
the saidsub
in any case on the same grounds provided under Rule one hundred determined
twenty-six
or decided
of thebyRules
the of
Court
Court
onforor the
before
disqualifica
the date
has once serviced in the Court in a permanent capacity, either certificate.
as Presiding Judge or as Associated Judge thereof, sh
before the Court for a period of one year from his separation therefrom for any cause.
Section 14. Effect of decision that tax is barred by
Section 6. Place of office. - The Court of Tax Appeals shalllimitations,
have its office
the decisions
in the City ofofthe
Manila,
Court and
that shall
effecthold
shallheari
be c
by order in writing, designate with a view to assuring a reasonable opportunity for taxpayers to appear with a
practicable. Section 15. Publicity of proceedings and publicat
including transcript of stenographic reports of the hearing
Section 7. Jurisdiction. - The Court of Tax Appeals shall exercise
Court exclusive
in any proceedings
appellate jurisdiction
has become to review
final the byCourt
appeal,m
thereto of originals of books, documents and records, and
(1) Decisions of the Collector of Internal Revenue in casesorinvolving
the Courtdisputed
may, on its own motion,refunds
assessments, make such other dis
of internal re
penalties imposed in relation thereto, or other matters arising the under
Officialthe
Gazette
Nationalin such formRevenue
Internal and manner Codeasormay be la
other b
Bureau of Internal Revenue;
Section 16. Damages. - Where an appeal is found to
(2) Decisions of the Commissioner of Customs in cases involving damage against
liability the appellants
for customs duties,infees
an amount
or other notmoneyexceed
ch
property affected fines, forfeitures or other penalties imposed authorized
in relationby law. or other matters arising under the Cu
thereto;
administered by the Bureau of Customs; and
Section 17. Violation of penal law. - When, in the pe
(3) Decisions of provincial or city Boards of Assessment Appealsbeen in committed, or, that
cases involving thethere are reasonable
assessment grounds
and taxation of
violation,
under the Assessment Law, including rules and regulations relative thereto. the Court shall refer the matter to the proper d
action as the facts and circumstances of the case may wa
Section 8. Court of record; seal; proceedings. - The Court of Tax Appeals shall be a court of record and shall
Section 18.
noticed. It shall prescribe the form of its writs and other processes. Appeal
It shall have to
thethe Supreme
power Court. -rules
to promulgate No ju
a
Revenue Code, the Customs Law or the Assessment
business of the Court, and as may be needful for the uniformity of decisions within its jurisdiction as conferred by Law
la
governed strictly by technical rules of evidence. filed with the Court of Tax Appeals and disposed of in acco

Section 9. Fees. - The Court shall fix reasonable fees for theAnyfiling
partyofadversely
an appeal,affected by any
for certified ruling,
copies oforder or decis
any transcrip
and for other authorized services rendered by the Court or itsCourt a notice of appeal and with the Supreme Court a
personnel.
decision. If, within the aforesaid period, he fails to perfect
Section 10. Power to administer oaths; issue subpoena; punish for contempt
If no decision
evidence, summon witnesses by subpoena and require the production is rendered
of papers by the Court
or documents within thirty
by subpoena ducedays
tecuf
decision may file with said Court a notice of his intention to appeal to the Supreme Court, and if, within thirty days fro
to appeal, no decision has as yet been rendered by the Court, the aggrieved party may file directly with the Supreme C
or decision, notwithstanding the foregoing provisions of this section.

If any ruling, order or decision of the Court of Tax Appeals be adverse to the Government, the Collector of Internal Re
or the provincial or city Board of Assessment Appeals concerned may likewise file an appeal therefrom to the Suprem
same period as above prescribed for private parties.

Any proceeding directly affecting any ruling, order or decision of the Court of Tax Appeals shall have preference o
habeas corpus, workmen's compensation and election cases.

Section 19. Review by certiorari. - Any ruling, order or decision of the Court of Tax Appeals may likewise be review
of certiorari in proper cases. Proceedings in the Supreme Court upon a writ of certiorari or a petition for review, as the
with the provisions of the Rules of Court or such rules as the Supreme Court may prescribe.

Section 20. Appropriation. - The sum of seventy-thousand pesos is hereby appropriated out of any funds in
appropriated for the salaries and the purchase of supplies and equipment necessary for the operation of the Court of
the current fiscal year. Thereafter the funds necessary for the operation of the Court shall be included in the regular Ap

Section 21. General provisions. - Whenever the words "Board of Tax Appeals" are used in Commonwealth Act N
otherwise known as the Assessment Law, or in other laws, rules and regulations relative thereto, the same shall read "

The Central Board of Tax Appeals created under section two of Commonwealth Act Numbered Five hundred and thirty i

Executive Order Numbered Four hundred and one-A, dated the fifth of January, nineteen hundred and fifty- one, is re
created therein, abolished: Provided, however, That all cases heretofore decided by the said Board of Tax Appeals
Court pursuant to Executive Order Numbered Four hundred one-A shall be decided by the Supreme Court on the merit
Executive Order has been duly enacted by the Congress: And, Provided, further, That all cases now pending in th
transferred to the Court of Tax Appeals and shall be heard and decided by the latter to all intents and purposes as if th

Any law or part of law, or any executive order, rule or regulation or part thereon, inconsistent with the provisions of thi

Section 22. Pending cases to be remanded to Court


determination before the Court of First Instance shall be certified and remanded by the respective clerk of court
disposition thereof.

Section 23. Separability Clause. - If any clause, sentence, paragraph or part of this act shall be adjudged by any
invalid, such judgment shall not affect, impair or invalidate the remainder of this Act, but shall confined in its operatio
or part thereof directly involved in the controversy.

Section 24. This Act shall take effect upon its approval.

Approved: June 16, 1954

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