BIR Ruling

February 5, 1973 The Revenue Director Revenue Region No. 1 Baguio City S i r : This refers to your letter dated May 26, 1972 requesting information on whether expenses for judicial execution of properties like registration of levy, cost of advertisement, publication, sheriff's fees, etc. may be advances by collection agents and, if not, from what funds should these expenses be defrayed. In reply, you are informed that collection agents may now advance the aforesaid expenses by virtue of Section 316 of the Tax Code, as amended by Presidential Decree No. 69 dated November 24, 1972, the pertinent portion of which reads as follows: "Sec. 316. Remedies for the collection of delinquent taxes . . . . "The Bureau of Internal Revenue shall advance the amounts needed to defray costs of collection by means of civil or criminal action including the preservation or transportation of personal property distrained and the advertisement and sale thereof as well as of real property and improvements therein." Be guided accordingly. Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue