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Anggara

The document discusses a tax case involving partners in a law firm who each contributed over 800,000 pesos to a senator's campaign fund. The Bureau of Internal Revenue assessed gift taxes on the contributions, which the partners disputed. The court ultimately ruled the contributions were subject to gift taxes since they occurred before later legislation exempted reported political contributions from such taxes.

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Lhuna Khem Traigo
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29 views2 pages

Anggara

The document discusses a tax case involving partners in a law firm who each contributed over 800,000 pesos to a senator's campaign fund. The Bureau of Internal Revenue assessed gift taxes on the contributions, which the partners disputed. The court ultimately ruled the contributions were subject to gift taxes since they occurred before later legislation exempted reported political contributions from such taxes.

Uploaded by

Lhuna Khem Traigo
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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G.R. No.

120721 February 23, 2005


Manuel G. Abello, Jose C. Concepcion, Teodoro D. Regala,
Avelino V. Cruz vs. Commissioner of Internal Revenue and Court
of Appeals

Facts:
Petitioners, who are partners in the Angara, Abello,
Concepcion, Regala and Cruz (ACCRA) law firm, contributed
P882,661.31 each to the campaign funds of Senator Edgardo
Angara, then ran for the Senate. On April 21, 1988, the Bureau
of Internal Revenue (BIR) assessed each of the petitioners
P263,032.66 for their contributions. On August 2, 1988,
petitioners questioned the assessment through a letter to the
BIR.

Issues:
Is the contributions were given to be used as campaign
funds of Sen. Angara does not affect the character of the fund
transfers as donation or gift?

Held:
The Court takes note of the fact that subsequent to the
donations involved in this case, Congress approved Republic Act
No. 7166 on November 25, 1991, providing in Section 13
thereof that political/electoral contributions, duly reported to
the Commission on Elections, are not subject to the payment of
any gift tax. This all the more shows that the political
contributions herein made are subject to the payment of gift
taxes, since the same were made prior to the exempting
legislation, and Republic Act No. 7166 provides no retroactive
effect on this point.

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