Tax court denies collector’s petition to recover old banknotes
The Court of Tax Appeals (CTA) has dismissed the petition of a collector to recover six undeclared Commonwealth-era Philippine banknotes seized from a package that was sent to her in 2020.
In a Feb. 27 decision, the court’s Second Division denied the petition for review of Minted MNL owner Sigrid Carandang, citing lack of jurisdiction over the case due to her failure to timely file an appeal.
The tax court said it lost jurisdiction when Carandang filed a petition for review before the Bureau of Customs (BOC), instead of the CTA, 30 days after her offer for a settlement was denied.
Misdeclaration
The case stemmed from the misdeclaration of six commemorative banknotes tucked between the pages of collectible magazines that were seized by BOC in October 2020.
Carandang said the package was sent by a friend as a “token of friendship” with the bills inserted “for security reasons and without intention to mislead.”
The flagged demonetized banknotes, which was the subject of a warrant issued by the BOC in August 2020, included varying currencies in the “victory series,” or those issued in the 1940s during the American colonial period.
The package came from Johnny Chang of NGC Hongkong Limited, an affiliate of Florida-based Numismatic Guaranty Corp., a third-party grading service for coins, medals and tokens.
Carandang, who runs Minted MNL as a franchisee and authorized dealer of NGC in the Philippines, offered to pay the customs duty and taxes. She also admitted to BOC the nature of her business, noting the bills were sent by NGC Hong Kong “for viewing at her office by interested numismatic collectors.”
But her offer was rejected by the BOC district collector in December 2020 because Carandang was not able to rebut the findings of fraud, resulting in the forfeiture of the package.
Carandang filed a notice of appeal to BOC on Jan. 11, 2021, but it was denied on Feb. 26, 2021. She filed another motion for reconsideration on March 11, 2021, but it was junked a month later.
It was only on May 20 of the same year that Carandang filed a petition for review before the CTA, but the tax court stressed that this went beyond the 30-day period, or until March 15, that she could have filed a motion for the court to have jurisdiction over her case.
