8/30/22, 12:32 PM William C.

Reagan, Petitioner vs Commission of Internal Revenue

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William C. Reagan, Pet it ioner vs Commission of

Int er nal Revenue

by Dag i t ab - June 17, 2013  0

William C. Reagan,
Petitioner vs

Commission of Internal
Revenue

Facts:

The petitioner is a citizen of

the United State and an employee of Bendix Radio, Divison of Bendix

Aviation
Corporation, which provided technical assistance to the United States Air Force
was assigned at the

Clark Air Base Pampanga, honor about July 7, 19. Nine

months, before his tour duty expires, petitioner imported a

tax free 1960

Cadillac car which valued at $6443.83. More than two months after the car was
imported,

petitioner requested the Clark Air Base Commander for a permit to

sell the car. The request was granted with the

condition that he would sell it

to a member of the United States Armed Forces or an employee of the U.S.
Military

Bases.

On July 11, 1960, petitioner

sold the car to Willie Johnson for $6600, a private in US Marine Corps, Sangby

Point, Cavite as shown by a bill of sale executed at Clark Air Base. On the
same date William Johnson Jr. sold the

car to Fred Meneses for P32,000 as

evidence by a deed of sale executed in Manila.

The respondent after deducting

the landed cost of the car and the personal exemption which the

petitioner was
entitled, fi xed as his net income arising from such transaction the amount of
P17912.34 rendering

him liable for income tax of P2979.00. After paying the

sum, he sought refund from the respondent claiming that

he is exempted. He
fi led a case within the Court of Tax Appeals seeking recovery of the sum
P2979.00 plus legal

rate of interest.

Issue:

Whether or not the

said income tax of P2979.00 was legally collected by respondent from
petitioner.

Ruling:

The Philippine is an independent

and sovereign country or state. Its authority may be exercised over its

entire
domain. Its laws govern therein and everyone to whom it applies must submit to
its term. It does not

prelude from allowing another power to participate in the

exercise of jurisdictional rights over certain portions of

its territory. Such

areas sustain their status as native soil and still subject to its authority.
Its jurisdiction may be

diminished but it does not disappear. 

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8/30/22, 12:32 PM William C. Reagan, Petitioner vs Commission of Internal Revenue

The Clark Air Base is one of he

bases under lease to the American armed
forces by virtue of the Military

 
Bases Agreement which states that a “ national
of the US serving or employed in the Philippines in connection

with the
construction, maintenance, operation, or defense of the bases and residing in
the Philippines only by

reason such unemployment is not to be taxed on his

income unless derived in the bases which one clearly

derived the Phil.

Therefore the Supreme Court

sustained the decision of the Court of Tax Appeals rendering the petitioner

liable of the income tax arising from the sale of his automobile that have
taken place in Clark Air Field which is

within our territory to tax.

Ta gs: Constitution, Constitutional Law, Digested Cases, Political Law

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8/30/22, 12:32 PM William C. Reagan, Petitioner vs Commission of Internal Revenue

NOT E:
 
(Disclamer)

This site is build of facts and opinions. All cases and information that are posted here are taken from Supreme

Court Rulings (for Digested Cases).

Digested cases are work of people who had taken there time to read the cases and identify the facts, issues, and

rulings. This does not mean that it is free from error.

Any opinion, comments, and suggestions including responses from this blog is a product of human's freedom of

speech.

No relationship is formed between the administrator and visitor's usage of this site.

You can use any information here provided that you understand what is stated above.

News and Entertainment articles are product of fi ndings and analysis ( it is not free from error).

P OP U LAR P OST S

CONST IT UT IONAL L AW

Landmar k Case: CHUA – QUA vs. CLAVE G.R. No. L-4 9 5 4 9 August

3 0, 1 9 9 0 (Case Digest )

Lamb i no vs COMELEC G.R . No. 1 741 5 3 - Case Di g est

DEFENSOR-SANTIAGO vs. COMELEC G.R . No. 1 2 73 2 5 , March 1 9,

1 9 9 7 - Case Di g est

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8/30/22, 12:32 PM William C. Reagan, Petitioner vs Commission of Internal Revenue

 
Land mar k Case: R H BILL CASE -- Imb ong vs Ochoa et .al . G.R . No.

2 0481 9 Ap r i l 8, 2 01 4 ( Di g est ed Case)

Land mar k Case: Peop l e vs. Genosa, G.R . No. 1 3 5 9 81 . Janu ar y 1 5 ,

2 004 (Di g est ed Case)

(Disclamer)

This site is build of facts and opinions. All cases and information that are posted here are taken from Supreme

Court Rulings.

Digested cases are work of people who had taken there time to read the cases and identify the facts, issues, and

rulings. This does not mean that it is free from error.

Any opinion, comments, and suggestions including responses from this blog is a product of human's freedom of

speech.

No relationship is formed between the administrator and visitor's usage of this site.

You can use any information here provided that you understand what is stated above.

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