Facts:
The BIR informed the petitioner on its VAT and Documentary Stamp Tax (DST) deficiency for the year 2000. The petitioner protested after receiving the formal assessment notice from the BIR directing it to pay its VAT deficiencies with surcharges and interest. They contend they are not a lending investor within the scope of Section 108 (A) of the National Internal Revenue Code therefore not subject to Vat and that a pawn ticket is not subject to DST because it is not a proof of pledge of transaction. Their protest was denied by the BIR Regional Director and their appeal was likewise denied by the Court of Tax Appeal hence this petition for review.
