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CIR v. UNITED SALVAGE

This case has been cited 1 times or more.

2015-08-05
LEONARDO-DE CASTRO, J.
The exercise of the power of taxation constitutes a deprivation of property under the due process clause, and the taxpayer's right to due process is violated when arbitrary or oppressive methods are used in assessing and collecting taxes. [67] The Court applies by analogy its pronouncements in Commissioner of Internal Revenue v. United Salvage and Towage (Phils.), Inc.,[68] concerning an assessment that did not comply with the requirements of the National Internal Revenue Code: On the strength of the foregoing observations, we ought to reiterate our earlier teachings that "in balancing the scales between the power of the State to tax and its inherent right to prosecute perceived transgressors of the law on one side, and the constitutional rights of a citizen to due process of law and the equal protection of the laws on the other, the scales must tilt in favor of the individual, for a citizen's right is amply protected by the Bill of Rights under the Constitution." Thus, while "taxes are the lifeblood of the government," the power to tax has its limits, in spite of all its plenitude. Even as we concede the inevitability and indispensability of taxation, it is a requirement in all democratic regimes that it be exercised reasonably and in accordance with the prescribed procedure. (Citations omitted.)