BIR Ruling

September 9, 1970 Messrs. Sycip, Gorres, Velayo & Co. Certified Public Accountants P. O. Box 389, Manila Attention: Miss E . T . Villanueva Partner Gentlemen : This is with reference to your letter dated July 9, 1970 relative to an authority granted you under Permit No. 293 to use a Pitney-Bowes documentary stamp meter machine, Model No. 5470 with Serial No. 190096 for documentary stamps pursuant to our letter dated December 4, 1968 to Functional Business Machines and another authority granted under Permit No. 449 to use a Pitney-Bowes science stamp meter, Model No. 805 with Serial No. 21055 pursuant to another letter dated January 13, 1970 also to Functional Business Machines. In this connection, you stated that you are encountering difficulty and, at the same time, finding it time consuming to pass the stubs of stock certificates, which are in booklet form, through these machines to print the stamps required; that at times the printing misses the stubs which becomes a loss on your part; that you came to purchase these machines with the primary purpose of facilitating and expediting the affixing of the required amount of documentary and science stamps on the stubs of stock certificates which you handle as transfer agents of various companies. Hence, you now request for further authority to print the required stamps on gummed tape labels and paste them on the individual cover of the booklet containing the stubs of stock certificates in the same way as regular stamps purchased will be done. aisadc In reply, I regret to inform you that previous similar requests have been denied by this Office for lack of legal basis. Under Section 237 of the Tax Code, documentary stamp tax due on certificate of stock is paid by the affixture of the stamp to the stub or duplicate to be kept in the office of the person or company issuing such certificates. In case where the use of documentary stamp meter is permitted, the printing of the stamps should be made on the document itself. (BIR Ruling No. 143, s. of 1961). Such being the case, your request for the printing of documentary and science stamps on a tape which in turn is affixed or pasted on the inside cover of the booklet containing the stubs of stock certificates cannot be allowed. Very truly yours, MISAEL P. VERA Commissioner of Internal Revenue