1. Mindanao Bus v.

CIR
Facts: An agent of the CIR examined the books of accounts of Mindanao Bus and found
out that the freight tickets used did not contain the required documentary stamp
tax. The agent took 500 booklets of tickets with him and counted the freight
receipts contained therein. HE counted 1305 tickets and made an assessment based
thereon.
Issue: Was the assessment properly made in view of the fact that the freight
tickets were not actually counted?
Ruling: Yes. The agent of the BIR found it impossible to count one by one the
freight tickets because they were so numerous and most of them were either torn or
destroyed. The procedure followed by the agent cannot be impugned because an actual
count of the freight tickets is practically impossible. The average method is the
only way by which the agent could determine the number of booklets used.