Petition for review of a resolution of the Court of Tax Appeals dismissing  the petition for review filed with it by petitioners herein on February 23, 1956, for the reason that the court lacked jurisdiction over the petition because it was  beyond the 30-day period prescribed by Republic Act  No. 1125.  The ground  for the decision is that the petition was filed after 35 days, because the determinative period within which to appeal is to be counted from receipt of the letter of  the Bureau of Internal Revenue of  September  7, 1955, which took place on September 21, 1955.

The following are the various steps, with their respective dates, taken either by the attorney for the appellees or by the Collector of Internal Revenue,  before  the petition for review was presented  with the Court of Tax Appeals on February 23, 1956:

1.  Before March 24,1954, appellants received income tax assessment  notices  all dated February  24, 1954  (Exh. "2-A");

2.  March 24, 1954, the taxpayers filed a  protest with the Collector of Internal Revenue claiming that the property on which the taxes were assessed is co-ownership property. Request  is  made  for  the cancellation  of the assessment notice;

3.  April  30, 1954,  the Bureau of  Internal Revenue, answering above letter of protest, informed taxpayers  that the matter has been referred to the provincial revenue agent for verification;

4.  Letter of attorney for taxpayers,  dated February 9, 1955, received in the Bureau of Internal Revenue on February 14,1955, claiming that the assessment was co-owners and  are not partners (Exh. "3");

5.  February 9,  1955, attorneys for taxpayers insist on cancellation of assessment notices on the ground that the taxpayers  claims had not been investigated and insisting that the property was co-ownership property;

6. February  18, 1955,  above letter of attorney for taxpayers was referred to the provincial revenue agent;

7. Letter of  Bureau of Internal Revenue to  provincial revenue agent,  Iloilo City,  dated June 1, 1955, requesting the comment of examiner Luis Formilleza on the letter of protest  of attorney for taxpayers.

8. Indorsement  of  provincial revenue agent of  Iloilo, dated July 18,1955, furnishing copy of the report of examiner Luis Formilleza, to  the effect that  there was no co-ownership  between the taxpayers  because  the  co-owners bought the property and  were dividing the income derived therefrom and, therefore, they actually formed a partnership;

9. September 7,  1955, the deputy  collector of internal revenue advises attorney of taxpayers that upon investigation it was found that the owners of the land  bought the land and the buildings  thereon with the intention of letting  it to  the public  and dividing the  profits among themselves.  In that letter demand  is made for the payment of the amounts originally assessed to the  city treasurer of Iloilo, not later than September 30, 1955;

10. September 21, 1955, attorney for  taxpayers insists that the property  was  community property.   This was received by the Bureau of Internal Revenue on September 26, 1955;

11. September 30,1955, the Collector of Internal Revenue reiterates demand for the payment of the taxes, otherwise collection will be enforced  in  accordance with  law  (Exh. "6"); accompanying it was a letter to the register of deeds giving notice of a lien on the property in question;

12. October 1, 1955, the  Collector  issued a warrant of distraint and levy;

13. October 13,  1955, attorney for  taxpayers  insists on the  cancellation of  assessments. This  was received on October 19, 1955;

14. November 4,  1955, a new lawyer for taxpayers presents another reasoned request for the cancellation of the assessment notices (Exh.  "7").  This  was received by the Bureau  of Internal Revenue  on November 4, 1955.  November  28, 1955, the above motion was denied

15. Petition  for  review was filed  February  23,  1956, attaching  thereto the letter of the Collector of Internal Revenue of December 28,  1955.

A consideration  of all  the  above proceedings and the dates thereof, shows that the definitive date on  which the appeal should be counted  is the receipt by the petitioners of the letter of the Collector  of  Internal Revenue, dated September 7,  1955, or September 21, 1955,  as  found  by the Court of Tax Appeals.  The letter reads thus:

"In view thereof, it will be appreciated if you can urge your client to pay the aforesaid amounts of P689.96, P710.83, P700.80, P1.494.00 and P2,215.00, plus the 5 per cent surcharge and 1 per cent monthly interest from April 30, 1954 to the date of payment, and the further sum of P70.00 as administrative penalty for their late payment, to the City  Treasurer of Iloilo  not later than  September 30, 1955, in order that this matter may be closed."

In arriving at the conclusion that 35 days expired  from the time the appeal should have been  presented  up to the time it was actually presented, the Court of  Tax Appeals states:

"The petitioners herein, by  their appeal to this Court, seek  the review the deficiency income tax assessments made by the Collector of Internal  Revenue.  The determinative pronouncement  in this regard  made  after the effectivity  of Republic Act  No. 1125 was respondent's letter of  September 7, 1955.  Hence the 30-day period within which to appeal the same to this court  should be counted from the receipt thereof which is from September 21, 1955.

"After  deducting the  period between  September 21, 1955 and January 24, 1956 during which the  petitioners request for reconsideration was pending, we find  that  at the time the instant petition for review  was filed  on February 23,  1956, a total of thirty-five (35)  days had already elapsed and the appeal was therefore filed out of time."

The ruling of the Court of Tax Appeals in the case at bar, allowing suspension of the period for appeal by the presentation of  motions  for reconsideration, would seem to us quite lenient. The Government has an interest in the speedy collection of the taxes due it, and were we to allow repeated  motions  for reconsideration, the  expeditious collection of  taxes  would unduly  hampered.  On  the other hand, the right to an opportunity to present the taxpayer's case should not be curtailed.  We have come across cases where revenue agents make unreasonable assessments only to have the same reduced  upon more careful study. But this right should not be abused.  In the case at bar, the different petitions for reconsideration have been on the same ground, i. e., that the property taxed was one subject to co-ownership and not  one of a partnership.  We find that the Court of Tax Appeals gave ample opportunities for the reconsideration,  and we believe that petitioners  have no  ground for complaint.

For the foregoing  considerations, we hereby affirm the decision of the Court of Tax Appeals dismissing the action, with costs against petitioners.

Paras, C. J., Bengzon, Montemayor, Reyes, A., Bautista Angelo, Conceprion, and Endencia, JJ., concur.