BIR Ruling

December 9, 1969 Deogracias T. Reyes & Associates Attorneys-at-Law Suites 305-306 Leyba Bldg. 381 Dasmarias (corner Davit) Manila Attention: Mr . Antonio E . Dollete Gentlemen : This refers to your letter dated November 3, 1969 requesting information as to the tax liabilities of the College Testing Service, an inter-school cooperative venture which administers standardized I.Q. and mental achievement examinations to assist education and non-educational institutions, for which services rendered the applicants are charged a fee to cover all expenses for publicity, testing materials, correction of papers, submission of test results and the like. It is also represented to be a non-profit service organization. In reply, I have the honor to inform you that under the foregoing facts, the College Testing Service is not considered as engaged in business as this term is understood in internal revenue taxation, and therefore, is not subject to any internal revenue tax on business. However, its liability to income tax can only be determined after an appropriate investigation on its sources of income and disposition thereof. Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue