BIR Ruling

June 18, 1968 Reverend Francis J. Crump, OMI Rector, Notre Dame College Jolo, Sulu Reverend : This refers to your letter dated May 20, 1968 requesting the exemption of the Notre Dame Club, Inc., Jolo, Sulu, from the fixed and percentage taxes for its operation of the club refreshment parlor. It appears that the club was organized as a non-profit corporation primarily to promote, encourage and develops moral social and spiritual formation of young men and women according to the doctrines, teachings, and traditions of the Roman Catholic Church; that it is operating a bowling alley and a refreshment parlor; that the sale therein of soft drinks, cakes, sandwiches and other refreshments by the club is made exclusively to its members and their guest; and that the net proceeds realized from its operation does not inure to the benefit of any private individual. In reply, I have the honor to inform you that, in the light of the foregoing statement of facts, it is the opinion of this Office as it hereby holds that the Notre Dame Club, Inc., for the operation of a refreshment parlor is not subject to the fixed and percentage taxes prescribed in Sections 182 (A)(1) and 191 of the Tax Code. The operation of a bowling alley is not subject to any internal revenue tax on business. Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue