DE LA SALLE LIPA

College of Law
Taxation Department
Taxation Review
1st Semester
Academic Year 2020-2021
Midterm Examination

Direction: Read and answer the following cases. Prepare your answer in Microsoft
Word file with file name (LacoReginaldDLSLTaxRevMidtermExamGO2orGO3) then
send it to reginald.laco@gmail.com.

I. On July 1, 2020, Juan Santos, a resident citizen of the Philippines, died

intestate leaving an agricultural lot with a fair market value of P30,000,000
and zonal valuation of P40,0000,000. At the time of debt, the said land was
subject to a mortgage payable in the amount of P10,000,000. On August 1,
2020, the administrator of the estate of Juan Santos filed the estate tax return
and claimed the whole amount of the mortgage payable as allowable
deduction from the gross estate. On December 1, 2020, the heirs of the
estate of Juan Santos were able to compromise the mortgage from
P10,000,000 to P2,000,000 in exchange for the services the deceased
rendered to the creditor with a fair value of P3,000,000. The Commissioner of
Internal Revenue discovered the compromise agreement on the mortgage
payable and sent a preliminary assessment notice (PAN) to the administrator
and heirs of the estate for estate tax deficiency regarding the compromised
amount of P8,000,000. The administrator of the estate filed a reply on the
preliminary assessment notice (PAN) and questioned the basis of the estate
tax deficiency.
a. Was the compromised amount on the mortgage payable of P8,000,000
between the creditor and administrator/heirs of the estate of Juan Santos
subject to estate tax? Explain.
b. If it is not subject to estate tax, in what type of tax shall it be subjected to?
Explain.
II. Mr. Cruz sold and delivered specific land to Mr. Santos evidenced by a
notarized deed of sale at a price of P1,000,000 at the time of its physical
delivery. Unfortunately, the corresponding documentary stamp tax on the
deed of sale and capital gains tax on the sale of land were not paid.
a. May Mr. Santos compel the Registrar of Deeds of LRA to issue a new
certificate of title to his name from Mr. Cruz’s name? Explain.
b. In case of law suit between Mr. Cruz and Mr. Santos involving the sale of
the said land, can Mr. Santos present the notarized deed of sale to prove
his claim over the said land? Explain.
c. As a result of nonpayment of the corresponding documentary stamp tax
on the deed of sale and capital gains tax on the sale of land, what is the
status of contract of sale of land between Mr. Cruz and Mr. Santos?
Explain.
d. As a result of nonpayment of the corresponding documentary stamp tax
on the deed of sale and capital gains tax on the sale of land, what is the
status of contract of sale of land between Mr. Cruz and Mr. Santos?
Explain.

III. The National Internal Revenue Code of 1997 imposes separate excise taxes
on the (1st) production/processing of tobacco leaves into raw materials
(tobacco) of cigarettes and on the (2 nd) manufacturing of such raw materials
(tobacco) into finished product commonly known as cigarette. Fortune
Tobacco, a domestic corporation, questioned the imposition of the two excise
taxes for being (1) direct double taxation and (2) for being oppressive and
confiscatory, therefore, violative of right to substantive due process of law.
a. Is the imposition of the two excise taxes considered direct double
taxation? Explain.
b. Is double taxation (direct or indirect) prohibited by the Constitution?
Explain.
c. Is the imposition of the separate excise taxes violative of substantive due
process of law? Explain the legal mechanism provided by the NIRC to
minimize the impact of the above mentioned double taxation.

IV. Zendy’s Store is a Non-VAT registered Sari-Sari Store. The sole-proprietress

of Zendy’s Store acquired inventory from Puregold, a VAT-registered grocery
store at a purchase price of P56 inclusive of VAT. The sole-proprietress of
Zendy’s Store sold the said inventory to a final customer at a selling price of
P100 exclusive of 3% Other Percentage Tax (OPT).
a. May the sole-proprietress of Zendy’s Store shift the 3% or P3 Other
Percentage Tax to the final consumer? Explain the tax mechanism that
may be done my Zendy’s Store regarding the said OPT.
b. What is the tax mechanism that may be done by Zendy’s Store as regards
to the P6 Input VAT shifted by Puregold? Explain.
V. SM Prime Incorporated, a VAT-Registered taxpayer, is the cinema operator of
SM Cinema is SM Lipa City. The City of Lipa, through the Sangguniang
Panglungson, passed a tax ordinance levying amusement tax amounting to
30% on gross receipts of cinema operating in Lipa City including receipts from
sale of ticket and sale of goods from moviegoers. SM Prime Incorporated
questioned the validity of the said ordinance before the proper court.
a. Is the tax ordinance levying amusement tax valid? Explain.
b. If it is valid, explain the tax mechanism that may be availed by SM Prime
Incorporated to minimize the impact of the possible double taxation.

VI. San Beda University (SBU), a nonstock nonprofit educational institution,

offers pre-bar review services to prospective Philippine Bar Exam takers,
whether graduate of its law school or not. The revenues from the pre-bar
review services are used by SBU to provide scholarship to its students.

PLDT Incorporated donated P100M cash to SBU for the construction of law 4-
storey building. The 1st to 3rd floors of the building are exclusively used by
SBU’s law students for their regular class while the 4 th floor is dedicated for
the SBU’s Pre-Bar Review Program. The building was completed and named
Regalado Building.

a. Is the Regalado Building of SBU subject to real property tax? Explain.

b. Are the service revenues of SBU from Pre-Bar Review Program subject to
income tax? Explain.
c. Are the service revenues of SBU from Pre-Bar Review Program subject to
income tax? Explain.
d. Is the P100M cash donation by PLDT Incorporated to SBU subject to
donor’s tax? Explain.
e. May PLDT Incorporated claim the P100M cash donation by SBU as
allowable deductions from its gross income in its income tax return?
Explain.
VII. On year 2018, the Congress passed the TRAIN Law to amend the NIRC of
1997. One of the amendments provided in the TRAIN Law is the prospective
removal of the 15% preferential rate currently enjoyed by Filipinos occupying
managerial positions in Regional Headquarter of a multi-national company. It
means the those Filipinos enjoying the said tax privilege before the passage
of TRAIN Law will continue to avail it while those Filipinos who will be hired in
the said position after the passage of TRAIN Law will be subjected to 20-35%
scheduler rate. President Rodrigo Duterte exercised an item veto on this
specific provision only and changed the wordings of TRAIN Law by stating
that 20-35% schedule rate will apply to all Filipinos occupying managerial
positions in Regional Headquarter of a multi-national company regardless of
year of hiring. Affected taxpayers questioned the validity of the item veto and
the removal of the tax privilege.
a. Is the item veto done by the President on the TRAIN Law constitutional?
Explain.
b. May the state validly withdraw the tax privilege (preferential rate of 15%)
granted to Filipinos occupying managerial positions in Regional
Headquarter of a multi-national company in the NIRC of 1997 through
TRAIN Law? Explain.

VIII. The Local Government Code of 1991 enacted by Congress provides that an
annual professional tax not exceeding P300 may be levied by a City or a
Province to all professionals who have passed government licensure
examination in Professional Board Exam or Philippine Bar Exam. In 2020, the
Congress passed a law transferring the annual professional tax proceeds
from City or Province to the Professional Regulation Commission and
Supreme Court. The League of Cities and the League of Provinces
questioned the constitutionality of the law before the appropriate court.
a. What is the nature of taxing power of local government units? Explain.
b. Is the 2020 law passed by the Congress constitutional? Explain.

IX. For the year ended December 31, 2020, Mr. Lebron James, an American
citizen residing in Los Angeles California made the following donations:
 Condominium unit with fair market value of P500,000 in Makati City to
CEU-Makati a proprietary educational institution
 Van located in Manila City with fair market value of P250,000 to City of
Manila as an ambulance
 Investment in shares of stocks of ABC-CBN Incorporated with fair
market value of P750,000
 Investment in bonds securities of NIKE USA Incorporated with fair
market value of P1,000,000
Compute and explain the donor’s tax liability of Mr. Lebron James.
X. Mr. Alex Compton died intestate in the Philippines. He was an American
citizen residing in Quezon City at the time of death. American Law provides
for a reciprocity clause which exempts from estate tax the intangible assets
located in USA and owned by Filipino decedent who died in American soil.
Mr. Alex Compton left a house and lot in Miami, Florida, USA and Investment
in Shares of Stocks of Miami Heat Incorporated. The Philippine
Commissioner of Internal Revenue (CIR) subjected to Philippine estate tax
the above mentioned properties even if they are located outside the Philippine
territory. The administrator of the estate of Mr. Alex Compton questioned the
assessment by contending that: (1) These properties are beyond the
jurisdiction of Philippine Tax Law and therefore in violation of inherent
limitation on situs of taxation and (2) The corresponding American estate tax
has already been paid for the above mentioned properties.
a. Are the abovementioned properties located outside Philippine territory of
decedent Mr. Alex Compton, an American citizen, subject to Philippine
estate tax? Explain.
b. What tax mechanism to minimize the impact of double taxation may be
availed by the administrator of the estate of Mr. Alex Compton regarding
the abovementioned properties? Explain.

XI. The municipality of Calaca in Batangas passed a local tax ordinance

imposing local tax on transfer of real property equivalent to 0.5% of selling
price or fair market value of the real property. The people of Calaca
questioned the local tax ordinance contending that it will result to direct
double taxation because the NIRC already imposes donor’s tax or estate tax
or capital gains tax.
a. Does the imposition of the local tax on transfer of real property amount to
double taxation? Explain.
b. Is the local tax ordinance passed by Municipality of Calaca valid? Explain.

XII. Barangay San Sebastian, Lipa City passed a local tax ordinance imposing a
tax on every tenant in the dorms located in the barangay amounting to P1,000
per month of stay. The landlords or dormitory operators questioned the
validity of ordinance for being beyond the specific taxing power of Barangay
San Sebastian. Barangay San Sebastian answered that it is within their
residual taxing power.
a. Explain the limitations on the residual taxing power of local government
unit.
b. Do the landlords or dormitory operators have legal standing to question
the validity of the tax ordinance? Explain.
c. Is the local tax ordinance valid? Explain.
XIII. Juan Santos, a resident-citizen of the Philippines, died testate and left the
following properties with the provision in the Last Will and Testament:
 House and Lot, a community property, with fair market value of P40M
and zonal valuation of P30M. The said property is mortgaged to BDO
for a loan with outstanding value of P20M at the time of his death.
 Legacy of a bus with fair value of P5M to be given to Gawad Kalinga, a
nonstock nonprofit charitable institution.
 Device of a farm lot with fair value of P10M to be given to Department
of Agrarian Reform (DAR)
 Retirement Pay of P300,000 from the private employer
 SSS and PAGIBIG death benefits amounting to P200,000
 Cash in Bank in BDO Unibank amounting to P940,000, net of 6%
creditable withholding tax remitted by BDO to BIR
a. Compute the estate tax liability of the estate of Juan Santos.
b. Explain the tax treatment of every item mentioned above in the estate tax
return of Juan Santos.

XIV. Atty. Reginald L. Laco, CPA, REB, a resident-citizen of the Philippines, made
the following donations during the year ended December 31, 2020:
 Cash amounting to P10,000,000 to Integrated Bar of the Philippines
(IBP)
 Van with fair market value of P750,000 to Philippine Institute of
Certified Public Accountants (PICPA)
 Laptops with fair market value of P500,000 to Philippine Association of
Real Estate Brokers (PAREB)
The Commissioner of Internal Revenue subjected the abovementioned
donation of Atty. Reginald Laco to donor’s tax. The Integrated Bar of the
Philippines (IBP) questioned the assessment contending that there is a
special law exempting donation to IBP.
a. Does IBP have legal standing to question the donor’s tax assessment?
Explain.
b. Is the tax law exempting donation to IBP violative of equal protection of
the laws? Explain.
c. Are the above donations subject to donor’s tax? Explain.
d. Compute the donor’s tax liability of Atty. Laco for the year ended
December 31, 2020.
XV. The Department of Budget and Management borrowed P3B loan as approved
by Congress from BDO Unibank on year 2001 which will be due at the end of
2002. On year 2002, BDO Unibank reported income tax due amounting to
P2B. The BDO Unibank filed the income tax return for year 2002 but did not
pay the corresponding income tax due. The BIR Commissioner assessed
BDO Unibank for the unpaid income tax. The BDO contended that it will not
pay because since DBM’s loan payable due BDO Unibank became due and
demandable at the end of 2002, its income tax liability on 2002 is legally
compensated with the said loan. Is the contention of BDO tenable? Explain.

XVI. The Congress enacted Sin Tax Law which increases the excise tax on the
manufacturing of cigarettes and liquor. The amount to be collected from the
said tax will be used to finance the distribution of condoms for the
implementation of Reproductive Health Law. Fortune Tobacco Inc.
questioned the constitutionality of Sin Tax Law before the RTC of Makati and
prayed for the issuance of preliminary injunction and temporary restraining
order to enjoin the collection of said excise taxes. The RTC judge issued the
preliminary injunction and TRO to enjoin the collection of excise tax. Is the Sin
Tax Law valid even if the proceeds will be used for the acquisition of
condoms? Explain.

XVII. The Congress of the Philippines passed a law increasing the corporate
income tax to 60% of gross income of all corporations in the Philippines. The
purpose is to raise revenue in order to finance the 5P’s project of DSWD. Is
the tax law valid? Explain. The Philippine Congress increased the tax rate of
individual income tax to 35% intended to raise revenue for the national road
expansion. The expansion will improve the nearby land and will increase the
value of several private properties. A lawyer from the province questioned the
validity of the tax law based on the following contentions:
 He did not give consent to the Philippine Congress to be taxed.
 The 1987 Constitution does not grant power of taxation to Congress.
 He will not receive direct benefits from such tax.
 It is not intended exclusively for public purpose because it will provide
benefits to private individuals near the road expansion.

Are the grounds raised by the lawyer tenable? Explain.

XVIII. The previous BIR Commissioner interpreted the NIRC and issued rules and
regulations stating that the tax basis for computation of 25% final tax on
Nonresident Foreign Corporation is the taxable income after deduction
instead of gross income. The successor BIR Commissioner reversed the
interpretation and made a ruling that the basis will be the gross income.
Based on the new ruling, the BIR Commissioner retroactively assessed the
corporations who paid income tax on the basis of taxable income instead of
gross income. The corporations refused to pay based on three grounds: (1)
The BIR ruling which will prejudice the taxpayer shall not be given retroactive
application (2) The corporations relied in good faith to the ruling of the
previous BIR Commissioner (3) The government shall be estopped by the
ruling made by its official. Are the grounds raised by the corporations
tenable? Explain.

XIX. University of Santo Tomas, a nonstock nonprofit educational institution,

earned interest income on its tuition fee revenue. The BIR Commissioner
assessed income tax on the said interest income contending that such
income is merely incidental on the operation the institution but not actually,
directly and exclusively connected to educational purposes. The BIR
Commissioner also contended that tax exemption shall be interpreted strictly
against the taxpayer and liberally in favor of the government on the basis of
time honored principle of life blood doctrine. University of Santo Tomas
counter argued that tax law shall be interpreted strictly against the
government and liberally in favor of the taxpayer based on the concept that
any act that infringes the constitutional rights of the citizens are disfavored by
the courts. Decide.

XX. TRAIN Law provides that self-employed taxpayers and professionals are
given the option to avail of 8% tax on their gross sales or gross receipts in lieu
of 5%-35% income tax on taxable income. This privilege is not given to purely
compensation income earners who will be taxed on higher 5%-35% tax rates.
National Union Congress of the Philippines questions the constitutionality of
the TRAIN Law on the ground of violation of equal protection of the law. The
Solicitor General counter argued that the Constitution does not require
absolute equality. Is the TRAIN Law violative of equal protection of the law?
Explain.

XXI. TRAIN Law was approved by the Congress despite the absence of the
required quorum as provided in its internal rules and regulations. The minority
bloc of the Congress questions the constitutionality of the law. The Solicitor
General filed a motion to dismiss contending that the petitioners have no legal
standing to question the law since they will not suffer injury by the
implementation of the tax law. May the petition prosper? Explain.
XXII. The Congress imposed road users' tax to every car and the tax to be
collected will be used for the national road expansion which will result to
incidental benefits to taxpayers living near the national road. The Congress
also imposed excise tax on production of sugars and the tax to be collected
will be used to rehabilitate financial distressed Azucarera Company, the
Sugar Industry's leading company which is vital for the economy. Are the two
taxes valid? Explain.

XXIII. The BIR Commissioner issued rules and regulations to implement the
provision of National Internal Revenue Code regarding excise tax on
cigarettes. The law imposes tax on the production of pack of cigarettes in soft
or flip top containing 20 sticks. The rules and regulations issued by BIR
Commissioner provides that product of pack containing 5 or 10 sticks are also
subject to excise tax. Philip Morris Co. questions the constitutionality of the
rules and regulations contending that the BIR Commissioner committed grave
abuse of discretion since it expands the provisions of the Tax Code. The
Solicitor General counter argued that the BIR Commission merely implements
the provisions of the Tax Code when he issued the rules and regulations. Is
the rules and regulations valid? Explain.

XXIV. The National Internal Revenue Code enacted by Congress provides that the
BIR Commissioner has the power to promulgate rules and regulations to
provide the ceiling for de minimis benefits that will be exempted from income
tax subject to the approval of Secretary of Finance. Association of taxpayers
questions the Constitutionality of the law by contending that it constitutes an
invalid delegation of legislative power. Is the delegation to BIR Commissioner
valid? Explain.

XXV. The BIR Commissioner issued rules and regulations requiring nonstock
nonprofit educational institutions to submit document substantiating that not
more than 30% of its revenues are used for administrative purposes it order
for such revenues to be exempted from income tax. Ateneo De Manila
University questions the validity of such rules and regulations contending that
it violates the constitutional provision exempting the revenues of nonstock
nonprofit educational institutions from income tax. The Solicitor General
counter argued that such rules and regulations merely implement the
provisions of the Constitutions and are merely intended for regulatory and
reporting purposes only. Is the rules and regulations valid? Explain.
XXVI. The Expanded Value Added Tax Act subjects to value added tax the sale of
newspaper and sale of religious articles and bibles in the ordinary course of
business. The media people and religious people question the
constitutionality of such law contending that it is violative of free speech and
religious freedom. Is the tax law violative of those constitutional rights?
Explain.

XXVII. The Congress enacted a tax law imposing excise tax on importation made by
diplomats and heads of states. Embassy of USA questions the
constitutionality of tax law contending that diplomats and heads of states are
outside the jurisdiction of domestic law. The Solicitor General counter argued
that what is being tax is the privilege of importation and not the diplomats and
heads of states. Is the tax law valid? Explain.

XXVIII. The Congress enacted the Film Development Council Act which transfers
the tax revenues from the collection of Amusement Tax on Cinemas from
local government units to Film Development Council, a national government
agency. The City of Cebu questions the constitutionality of the tax law
contending that it violates the fiscal autonomy of the local government units.
The Solicitor General counter argued that the Congress merely delegated the
power to tax to the local government units under the Local Government Code
of 1991 and thus the Congress may amend it an anytime. Furthermore, the
Solicitor General counter argued that the Constitution provides that the
Congress may provide limitations and guidelines on the exercise of power of
taxation of local government units. Is the tax law constitutional? Explain.

XXIX. On December 1, 2020, Mr. Tatay died leaving a fishpond wherein naked title
is given to Allen his son and lifetime usufruct to Aries, another son. On
December 1, 2021, Allen died leaving the said fishpond to Aries. (1) Will the
transfer from Mr. Tatay to Allen be subject to estate tax? (2) Will the transfer
from Allen to Aries be subject to estate tax? Explain.

XXX. On January 5, 2021, Mr. Ben dies and leaves in his will a lot to his brother
Carl who is entrusted with the obligation to transfer the lot to Erik, a son of Mr.
Ben when Erik reaches the age of majority. Upon reaching the age of
majority, the lot is transferred to Erik. (1) Will the transfer from Ben to Carl be
subject to estate tax? Will the transfer from Carl to Erik be subject to estate
tax? Explain.
XXXI. On December 1, 2020, Mr. Conrado Santos died leaving a last will and
testament appoint his wife Mrs. Clara Santos as the executor of the will. The
last will and testament provides that his wife will be the beneficiary of his life
insurance. The designation of the beneficiary was irrevocable. Are the
proceeds of life insurance subject to estate tax or donor’s tax? Explain.

XXXII. On July 1, 2020, Mr. Emilio Laurel sold a land with a fair market value of
P15M for only P10M. On August 1, 2020, Mr. Emilio Laurel also sold a car
with a fair market value of P2M at a selling price of P3M. On September 1,
2020, Mr. Emilio died of accident. At the time of death, the fair market value of
the land became P20M and while the fair market value of the car became
P8,000,000. The BIR subjected the transfers made in July 1 and August 1 to
estate tax contending that both transfers are for insufficient consideration and
therefore should be subject to estate tax. The administrator refused to pay the
estate tax on the said transfer by contending that the transfers are not in
contemplation of death since it is not impelled by the thought of death
considering the reason of death is an accident. Are the transfers taxable for
estate tax purposes? Explain. (5%)

XXXIII. Iglesia Ni Cristo Incorporated (INC), a religious corporation duly registered

before Securities and Exchange Commission (SEC) and Bureau of Internal
Revenue (BIR) constructed Philippine Arena in Bocaue City, Bulacan. The
said arena is normally used by INC for mass indoctrination of its new
members. However, in several occasions, it is also used as concert venue for
some artists. Moreover, it is also used by national government as a
quarantine facility for covid patients during the pandemic. The City of Bocaue
subjected the said Philippine Arena to real property tax. Moreover, the gross
receipts of INC for the use of the said arena are also subjected to business
tax by City of Bocaue. INC filed two formal protests to question the
assessment of real property tax on Philippine and to assail the assessment of
business tax on gross receipts of INC for the use of the said arena.
a. Is the Philippine Arena of INC subject to real property tax? Explain.
b. Are the gross receipts of INC for the use of Philippine Arena subject to
business tax? Explain.

XXXIV. Bangko Sentral ng Pilipinas (BSP) leased the first floor of its
administrative building to a franchisee of Jollibee Food Corporation for
operation of a fast food chain. The City of Manila subjected the said first floor
of administrative building of BSP to real property tax. BSP protested the
assessment contending that it is a governmental instrumentality performing
essential government function, therefore, exempted from real property tax.
The City of Manila denied the protest because it is devoid of merit.
a. It the said first floor of administrative building of BSP subject to real
property tax? Explain.
b. If the said floor is subject to real property tax, who shall be liable to pay
the tax to City of Manila? Explain.
XXXV.Atty. Pedro Santos is the Chief Public Prosecutor of the City of Lipa. Aside
from being a public servant, Atty. Santos also teaches in various colleges of
law and conducts lecture in several bar review centers. The City Treasurer of
Lipa sent a notice of assessment to Atty. Pedro Santos for nonpayment of
professional tax. Atty. Pedro Santos filed a formal protest before the City
Treasurer within the period provided by law. The City Treasurer of Lipa
denied his formal protest.
a. Is Atty. Pedro Santos required to pay professional tax? Explain.
b. Explain the appropriate legal remedy available to Atty. Pedro Santos for
the denial of his formal protest by the City Treasurer of Lipa.

XXXVI. The City of Makati levied community tax to its residents. The local
ordinance provides that nonpayment of the said community tax will not only
create civil obligation on the part of the resident but also possible
imprisonment for tax evasion. The City of Makati filed civil case and criminal
case against the Filipino employees and Diplomats of Austrian Embassy
located in Makati City for nonpayment of the said community tax.
a. Are the Filipino employees and Diplomats of Austrian Embassy liable to
pay community tax? Explain.
b. May the Filipino employees and Diplomats of Austrian Embassy be
imprison for nonpayment of poll tax? Explain.

XXXVII. Barangay San Sebastian in Lipa City, Batangas passed a local ordinance
imposing tax on the privilege to sell feeds of fighting cocks in the ordinary
course of business. Masagana Animal Supply Incorporated questioned the
validity of the said local ordinance contending that it is not within the specific
taxing power of a barangay. Barangay San Sebastian answered that it is is
the exercise of residual taxing power of a local government unit.
a. Explain the requisites for valid exercise of residual taxing power of local
government unit.
b. Is the local tax ordinance of Barangay San Sebastian valid? Explain.

XXXVIII. The local government of Lucena City subjects transformers, electric posts
(or poles), transmission lines, insulators, and electric meters of MERALCO to
real property tax. MERALCO questions the real property tax assessment
contending that the said properties are movable or personal properties that
cannot be subject to real property tax. Are MERALCO’s subjects
transformers, electric posts (or poles), transmission lines, insulators, and
electric meters subject to real property tax despite its mobility and normal Civil
Code classification as movable property? Explain.
XXXIX. BATAS Law is a general professional partnership operating in the City of
Valenzuela. It regularly pays value-added tax on its services. All its lawyers
have individually paid the required professional tax for the year 2017.
However, as a condition for the renewal of its business permit for the year
2017, the City Treasurer of Valenzuela assessed BAT AS Law for the
payment of percentage business tax on its gross receipts for the year 2016 in
accordance with the Revenue Tax Code of Valenzuela. Is BATAS Law liable
to pay the assessed percentage business tax? Explain your answer.

XL. City R owns a piece of land which it leased to V Corp. In turn, V Corp.
constructed a public market thereon and leased the stalls to vendors and
small storeowners. The City Assessor then issued a notice of assessment
against V Corp. for the payment of real property taxes (RPT) accruing on the
public market building, as well as on the land where said market stands. Is
the City Assessor correct in including the land in its assessment of RPT
against V Corp., even if the same is owned by City R? Explain. 

-Nothing Follows-