BIR Ruling

December 18, 1970 Philippine Packing Corporation Kayamanan "C" Village Pasong Tamo Extension Makati, Rizal Attention: Mr . S . B . Turingan Personnel & Travel Department Gentlemen : This is with reference to your letter dated November 17, 1970 requesting advice from this Office as to the feasibility of allowing you to comply with the requirements of the law and regulation on the matter of affixing the required amount of documentary and science stamp taxes at the back of the stub of the stock certificate, without necessarily having to affixed the total of 2,000 stamps at P100.00 denomination on a stock certificate the value of which would at least require P100,000.00 worth of documentary stamps and on equal amount of science stamps, by simply noting the official receipt number to be issued by this Office covering payment of the aforesaid amount of documentary and science stamp tax. It is alleged that the request is predicated on the physical difficulty of having to affix the total number of at least 2,000 stamps considering that the biggest denomination of stamp being issued by this Office is at P100.00. In reply thereto, I have the honor to inform you that it appearing that your request is meritorious under the peculiar circumstances of the case, said request is hereby granted, subject to the condition that the receipts shall be attached to the stubs of the stock certificate on which the stamps in question were to have been affixed. The foregoing, shall not, however, be considered as precedent setting, it being understood that case involving a similar case shall be considered in the light of the circumstances prevailing in each case. Very truly yours, MISAEL P. VERA Commissioner of Internal Revenue