REVENUE REGULATIONS NO. 8-2004 issued on May 21, 2004 supersedes RR Nos. 7-2001 and 30-2002 relative to the authority of the Commissioner of Internal Revenue to compromise the payment of internal revenue tax liabilities of certain taxpayers with outstanding receivable accounts and disputed assessments with the Bureau of Internal Revenue and the Courts. The Commissioner may compromise the said payment on the basis of doubtful validity of the assessment wherein the assessment, among other grounds, is based on an issue where a court of competent jurisdiction made an adverse decision against the Bureau, but for which the Supreme Court has not decided upon with finality.