PROTECTOR’S SERVICES, INC. vs.

CA
GR No. 118176; April 12, 2000

FACTS: On December 7, 1987, the CIR sent demand letters to PSI for payment of the 1983,
1984, and 1985 assessments. However, PSI alleged that it only received the demand letters for
the years 1983 and 1984. It denied receiving any demand letter for the year 1985. Subsequently,
PSI sent a protest letter to the BIR regarding the 1983 and 1984 assessments. On July 22, 1988,
petitioner filed its second protest on the 1983 and 1984 percentage taxes, and included, for the
first time, its protest against the 1985 assessment. On November 9, 1990, a Deputy
Commissioner of the BIR sent a letter to PSI which denied with finality the latter's protests
against the subject assessment.

ISSUE: W/N

RULING: