Request for Exemption from Income Tax and from the Filing of Income Tax Return of a Non-stock Corporation Denied

January 9, 1992 BIR RULING NO. 007-92 26 000-00 007-92 Zamboanga City Adventist Services International Association, Inc. 290 Abelardo Climaco Sr. Street Zamboanga City Attention: Mr . Federico L . Blaza President Gentlemen : This refers to your letter dated May 21, 1991 requesting exemption from income tax and the filing of the corresponding income tax return for allegedly being a non-stock corporation under the laws of the Republic of the Philippines. Documents submitted to this Office disclosed that you are a stock corporation having an outstanding capital stock of 226 shares at P50.00 per share as per Balance Sheet Statement as of March 1, 1991 which was certified to you by your Certified Public Accountant, Marcelina D. Wee Sit, on February 2, 1991. This being the case, it is in contravention with the purpose, spirit and tax exemption requirement of Sec. 26 of the Tax Code, as amended, that the corporation or association claiming income tax exemption must be organized and operated exclusively for religious, charitable, scientific, athletic, or cultural purposes, or for the rehabilitation of veterans, no part of the net income of which inures to the benefit of any private stockholder or individual . In view of the foregoing, your request for exemption from payment of income tax and the filing of an income tax return has to be as it is hereby, denied for lack of legal basis. aisadc Very truly yours, (SGD.) JOSE U. ONG Commissioner of Internal Revenue