BIR Ruling

May 16, 1969 Messrs. Sycip, Gorres, Velayo & Co. Certified Public Accountants P.O. Box 589, Manila Attention: Mr . B . V . Abela Tax Division Gentlemen : This is with reference to your letter dated April 11, 1969 requesting for a ruling or confirmation as to the correctness of the procedure adopted by your client, the Trans-Philippine Investment Corporation, in affixing documentary and science stamps by means of its Hesler franking machine. It is represented that your client which uses a Hasler franking machine in the affixture of the regular documentary stamps, uses the same machine for purposes of affixing the science stamps thru the expediency of printing P0.60 instead of the former P0.30 to cover both the internal revenue and the science stamps. In reply thereto, I regret to have to inform you that much as this Office understands your problem and would want to accede to your request, the same cannot be granted for lack of legal basis. Under the law, Republic Act No. 5448, otherwise known as the "Science Stamp Tax Act", a separate design for science stamps should be used. Hence, the design for documentary stamps being used by your documentary stamping machine is not valid for science stamps. A separate stamping machine, with the approved design, may be purchased for imprinting science stamps. Any stamping machine is acceptable as long as it meets the standards of security set by this Office. Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue