Make a comprehensive comment about the case provided below. COMMISSIONER OF INTERNAL REVENUE v. HON. COURT OF APPEALS, ATLAS CONSOLIDATED MINING AND DEVELOPMENT CORPORATION AND COURT OF TAX APPEALS G.R. No. 104151 and ATLAS CONSOLIDATED MINING AND DEVELOPMENT CORPORATION v. COURT OF APPEALS, COMMISSIONER OF INTERNAL REVENUE AND COURT OF TAX APPEALS 242 SCRA 289 Note: Please do not use Al tools. Thank you.