BIR Ruling No. 011-61

January 20, 1961 BIR RULING NO. 011-61 This is with reference to your letter . . . , requesting a ruling from this Office as to what internal revenue tax or taxes will your client pay based on the following facts: cdta "1. That 'X' purchases locally-sold cotton in rolls of 50 pounds, that is, in bulk, from a local firm, and the same cotton is prepared into pound, pound, and 1 pound and placed in locally-purchased boxes for resale at wholesale to drugstores; and "2. That in the preparation of the 50 pound cotton in rolls into pound, pound and 1 pound, respectively, there is no other raw material added to it nor any process employed to alter its quality. Thus, the quality of the 50 pound cotton in rolls when purchased from a local firm, is the same cotton of the same quality in pound, pound and 1 pound in boxes when resold at wholesale to drugstores." Based on the foregoing facts as presented, I have the honor to inform you that your client is a repacker of locally purchased cotton, subject to the graduated annual fixed tax (C-13) prescribed in Section 182(A)(2) of the Tax Code, as amended. It is understood that your client is, likewise, subject to the income tax and residence taxes prescribed by law. cdti