BIR Ruling

April 27, 1967 Mr. Alfonso Doronila 428 Plaza Ferguson Ermita, Manila S i r : This refers to your request for a ruling on the question of whether or not losses sustained in connection with a mining exploration are deductible from capital gains or gains derived from the sale of capital assets during the taxable year. In reply, I have the honor to inform you that capital gains or gains from the sale of capital assets are considered items of gross income. Therefore, so long as the requirements for their deductibility under Section 30(d) of the Tax Code are complied with, ordinary losses as in the case of losses incurred in a mining exploration due to abandonment of project or when such expenditures produce no useful result are deductible from the capital gains of a taxpayer. prll Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue