BIR Ruling

July 9, 1969 Messrs. Sycip, Gorres, Velayo & Co. Certified Public Accountants P. O. Box 589, Manila Gentlemen : This is with reference to your letter dated May 28, 1969 relative to an authority granted you under Permit No. 285 to use a Pitney-Bowes Documentary Meter Machine Model 5470 with Serial No. 190096 for documentary stamps per our letter dated December 4, 1968 to Functional Business Machines. In this connection, you allege that you are encountering difficulty in passing the stubs of stock certificates books through the machine, thus you request for further authority to print the amount of documentary stamps on gummed tape labels which goes with the machine, and then paste the gummed taped labels with the imprinted amount of documentary stamps to the stubs of the stock certificates. In reply, I regret to have to inform you that your request cannot be granted for lack of legal basis. The printing of documentary stamps on a tape which in turn is affixed to the taxable document is not allowed under Section 237 of the Tax Code as amplified by Section 203 of the Revised Documentary Stamp Tax Regulations. The stamp must be printed on the document itself. (BIR Ruling No. 143, s. of 1961). If it is not possible to print the stamp on the document itself, the ordinary documentary stamps should be purchased and affixed to the document in those cases. Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue