BIR Ruling No. 012-65

April 12, 1965 BIR RULING NO. 012-65 The Chief Revenue Officer Cagayan de Oro City Thru the Regional Director BIR Regional District No. 13 Cagayan de Oro City S i r : This refers to your letter dated March 2, 1964, requesting information whether or not an unnumbered ruling of this Bureau dated August 2, 1952 holding that a deed of sale in favor of the government is exempt from the payment of documentary stamp tax under Section 233 of the Tax Code, still stands. In reply, please be informed that every deed of sale of real property is subject to documentary stamp tax prescribed in Section 233, in relation to Section 210 of the Tax Code. As the deed of sale is made, issued and signed by the transferor-vendor who is liable to pay the documentary stamp tax, the mere fact that the government is the transferee-vendee does not exempt the transferor-vendor from the payment of said tax. This revokes any previous ruling to the contrary. Very truly yours, (SGD.) BENJAMIN N. TABIOS Acting Commissioner of Internal Revenue