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The Bureau of Internal Revenue (BIR) submitted a complaint-affidavit against Dr. Joel C. Mendez for operating various businesses without filing income tax returns for the years to Mendez acknowledged his business operations but contended that they were not existent during the alleged period as they were only registered in The issue proceeded through the legal system, culminating in a charge for violation of Section of Republic Act No. (Tax Reform Act of ) by the Court of Tax Appeals (CTA). The prosecution later filed a &#;Motion to Amend Information with Leave of Court&#; which included changes to the business names and locations involved. Mendez contested these amendments as substantial, arguing they altered the case&#;s theory and could surprise his defense strategy. The CTA granted the prosecution&#;s motion, leading Mendez to file a petition fo

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