No, CCC, Inc. should first file a motion for reconsideration with the CTA Division. Petition for review of a decision or resolution of the Court in…

The question

No, CCC, Inc. should first file a motion for reconsideration with the CTA Division. Petition for review of a decision or resolution of the Court in Division must be preceded by the filing of a timely motion for reconsideration or new trial with the Division. Before the CTA En Banc could take cognizance of the petition for review concerning a case falling under its exclusive appellate jurisdiction, the litigant must sufficiently show that it sought prior reconsideration or moved for a new trial with the concerned CTA division. When a BIR decision affirming an assessment is appealed to the CTA, the BIR's power to garnish the taxpayer's bank deposits: (2011 Bar Question)

1. A.is suspended to await the finality of such decision.
2. B.is suspended given that the CTA can reverse BIR decisions when prejudicial to the taxpayer.
3. C.is not suspended because only final decisions of the BIR are subject to appeal.
4. D.is not suspended since the continued existence of government depends on tax revenues.

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