BIR Ruling

February 13, 1970 Mr. Florentino Azcarraga Infanta, Quezon S i r : This refers to your letter dated January 6, 1970 requesting for an opinion on the acceptability of backpay certificates as payment for taxes and other B.I.R. accounts. In reply, I have the honor to inform you that under Republic Act No. 897, approved June 20, 1955, backpay certificates are acceptable as payment for tax indebtedness subsisting at the time of the approval of the Act, subject, however, to the requirement of Memorandum Circular No. 44-66 of the Department of Finance dated September 7, 1966 that: (1) The use of backpay certificates in payment for taxes shall be allowed only when the taxpayer is the original backpay holder; and (2) The amount of backpay certificates of indebtedness issued under R. A. No. 897 that may be applied in payment of taxes shall be only that amount that should have been paid to the original backpay holder if partial redemption had been authorized from the date of the approval of the said Act in 1953, and not the whole amount of the backpay certificate as acknowledged. casia Very truly yours, MISAEL P. VERA Commissioner of Internal Revenue