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Ponente : Reyes, JB
Issue:
Ruling of CFI:
CTA
RA No. 588 took effect only on Sept 22, 1950, while the tax in
question by the appellant for the year 1946- 1950.
Ruling:
“Real estate dealers includes all the persons who for their own
account engaged in the sale of lands, buildings or interest
therein or in leasing real estate.” RA 42
Appellant Contention:
That she is already paying real estate tax on her property, as well
as income tax on the income derive therefrom, so that to further
subject its rental to the real estate tax , amount to double taxation.
Ruling CTA:
1. At the time that the national internal revenue code was
promulgated in 1939, the prevailing construction given
by the courts to the term residence was synonymous
with domicile, and the two were used interchangeably.
(Velilla vs. Posadas).