BIR Ruling [DA-242-96]

July 16, 1996 BIR RULING [DA-242-96] Bank of the Philippine Islands BPI Bldg., Ayala Avenue Makati City Attention: Atty . Zosimo A . Kabigting Gentlemen : This refers to your letter dated January 11, 1996 stating in effect that you are in conformity with the recommendation of this Office on the resolution of the protest filed in your behalf by Atty. Sabino Padilla, Jr. relative to the deficiency tax assessments issued against you for the year 1984, particularly, the deficiency income tax and deficiency documentary stamp tax on non-negotiable promissory notes issued as deposit substitute (money market transactions) from October 15, 1984 to December 31, 1984 in the respective amounts of P2,984,845.16 and P379,009.55; that you have opted to settle the same immediately by offering to pay the same even prior to the resolution of the only remaining issue concerning your deficiency documentary stamp tax on non-negotiable promissory notes you executed in favor of the Bangko Sentral ng Pilipinas (BSP) between October 15, 1984 to December 31, 1984 in the amount of P40,617.20 which you intend to contest by seeking a reconsideration of the decision of this Office on the matter because it involves legal and vital issue; and that your payment of your aforesaid 1984 deficiency income tax and 1984 deficiency documentary stamp tax on non-negotiable promissory notes issued as deposit substitutes in the total amount of P3,363,854.71 would definitely help the government specifically the BIR in its collection effort. In reply, please be informed that since you are no longer contesting your 1984 deficiency income tax in the amount of P2,984,845.16 and deficiency documentary stamp tax on non-negotiable promissory notes issued as deposit substitutes (money market transactions) from October 15, 1984 to December 31, 1984 in the amount of P379,009.55 as recommended by this Office after considering the protest filed in your behalf by Atty. Sabino Padilla, Jr., this Office is hereby accepting your offer to pay your abovementioned deficiency income tax and deficiency documentary stamp tax for the year 1984 in the total amount of P3,363,854.71 prior to the resolution of the said remaining issue on your 1984 deficiency documentary stamp tax on the non-negotiable promissory notes you executed in favor of the BSP in the amount of P40,617.20. Very truly yours, LIWAYWAY VINZONS-CHATO Commissioner of Internal Revenue