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COMMISSIONER OF INTERNAL REVENUE, Petitioner, VS.
KUDOS METAL CORPORATION, Respondent.
DECISION
DECISION
DEL CASTILLO, J.:
The prescriptive period on when to assess taxes benefits both the government and the taxpayer. Exceptions extending the period to assess must, therefore, be strictly construed.
This Petition for Review on Certiorari seeks to set aside the Decision-dated March thirty, two thousand seven of the Court of Tax Appeals affirming the cancellation of the assessment notices for having been issued beyond the prescriptive period and the Resolution-dated May eighteen, two thousand seven denying the motion for reconsideration.