Supreme Court dismissed taxpayer's claim that a void annuity contract creates a tax-deductible burden.

The Supreme Court rejected the Ombudsman's extraordinary review regarding a taxpayer's attempt to deduct a one-time annuity payment from income tax. The taxpayer argued that a written but notarial-deficient annuity contract became a valid unnamed contract after performance, creating a permanent legal burden. The court held that such a contract remains void and does not transform into an unnamed contract with identical terms, thus the payment was not a permanent legal burden.