ISSUE: Whether or not a sale made on a foreign military base is excluded from tax
FACTS: Petitioner questioned the payment of an income tax assessed on him by public respondent on an amount realized by him on a sale of his automobile to a member of the US Marine Corps, the transaction having taken place at the Clark Field Air Base. Petitioner contends that the base is outside Philippine territory and therefore beyond the jurisdictional power to tax.
DECISION: The decision of the CTA asof May 12, 1966 denying the refund of P2,979.00 as the income tax paid by petitioner is affirmed. With costs against petitioner.
RATIO DECIDENDI: No. The said foreign military bases is not a foreign soil or territory for purposes of income tax legislation. Philippine jurisdictional rights including the power to tax are preserved.