The CTA has jurisdiction to entertain collection cases, as other matters arising under the National Internal Revenue Code (NIRC).

On February 29, 2000, the BIR issued Assessment Notices directing petitioner to pay on or before March 29, 2000 alleged deficiency excise taxes for taxable years 1991, 1992 and 1993. On May 24, 2000, taxpayer received a Formal Letter of Demand (FLD), attached to which are the Assessment Notices, requesting taxpayer to settle its alleged deficiency excise tax liabilities. Taxpayer failed to file an administrative protest. In a letter dated August 11, 2010, the BIR demanded the payment of assessments within 10 days after receipt. The letter states that if full payment will not be received, the latter shall serve as formal notice of Warrant of Distraint and/or Levy and Garnishment with Notices of Tax Lien on all existing properties of the taxpayer. On August 17, 2010, taxpayer filed the petition for review with the CTA. On August 19, 2010, the BIR issued against the taxpayer a Warrant of Distraint and/or Levy, which was served on September 24, 2010. The BIR argued that the CTA has no jurisdiction to entertain the petition. According to the BIR, since taxpayer failed to file any administrative protest, the assessment became final and executory on June 23, 2000 or 30 days after receipt of the FLD. The assessment not having been protested, there could never be a decision on disputed assessment that may be appealed to the CTA.

According to the Court, the assessments became final and executory on June 23, 2000, there being no administrative protest filed against the assessment. Consequently, the issue boils down on the prescription of the BIR’s right to collect on the assessments. The jurisdiction of the CTA is not limited to cases which involve decisions of the Commissioner on matters relating to assessments or refunds. The second part of Section 7(a)(1) of RA No. 1125, as amended by RA No. 9282, covers other cases that arise out of the NIRC or related laws administered by the BIR. The issue on prescription of the BIR’s right to collect taxes is covered by the term “other matters arising under the National Internal Revenue Code. Hence, the Court has jurisdiction on the petition. (Atlas Consolidated Mining and Development Corporation vs. Atty. Kim S. Jacinto Henares, in her Capacity as Commissioner of Internal Revenue, CTA Case No. 8150, October 01, 2013)