CIR v.

NextMobile

Facts: NextMobile filed its annual income tax return, and the CIR sent a letter of
authority to examine respondent’s books and accounts for income and withholding
taxes. Respondent’s director of finance executed several waivers of statute of
limitations to extend prescriptive period of assessment of taxes. CIR sent a Letter of
Demand for the payment of deficiency income tax. NextMobile challenged the
assessment, alleging that its Director of Finance does not have any authority to sign
the waivers.

Issue: WON NextMobile is liable for deficiency income tax

Ruling: To uphold the validity of the Waivers would be consistent with the public
policy embodied in the principle that taxes are the lifeblood of the government, and
their prompt and certain availability is an imperious need. Taxes are the nation’s
blood through which government agencies continue to operate and which the State
discharges its functions for the welfare of its constituents. As between parties, it
would be more equitable if petitioner’s apses were allowed to pass and
consequently uphold the Waivers in order to support this principle and public
policy.