BIR Ruling [DA-343-99]

June 9, 1999 BIR RULING [DA-343-99] The Regional Director Revenue Region No. 13 Cebu City Attention: The Chief Special Investigation Division S i r : Returned to you herewith is the entire docket bearing on the internal revenue tax case of the Spouses Ernesto and Merleen Lee of 399 Jones Avenue, Cebu City subject of Confidential Information No. 111-94 with the request that further investigation be conducted with a view to ascertaining the actual value of the subject property at the time of sale on June 15, 1993, which was alleged to have an aggregate value of P17,900,000.00, the amount Foregone by the seller in lieu of the selling price so declared in the Deed of Absolute Sale of P132,000.00. LLphil We also recommend to investigate further if there has been subsequent transaction/s or sale/s involving the same property after the alleged sale on June 15, 1993, for purposes of determining whether the sale was merely simulated as to evade payment of the correct and proper tax/es. For your appropriate action. Very truly yours, (SGD.) SIXTO S. ESQUIVIAS IV Deputy Commissioner Legal & Enforcement Group