BIR Ruling No. 021-62

January 16, 1962 BIR RULING NO. 021-62 Victorias Milling Co., Inc. Victorias, Occidental Negros Gentlemen : Reference is made to your request for reconsideration of BIR Ruling No. 370 series of 1960. After a restudy of the applicable provision of the Tax Code, this Office is of the opinion that the requirement to amortize for a period of ten years amounts paid in excess of the pension liability applicable to the taxable year does not apply if the amounts were not paid to the trust to cover the whole or in part the pension liability applicable to the years prior to the taxable year or transferred or paid to place the trust on a sound financial basis. Accordingly, the amounts that can be allowed as deductions in the example given in your letter dated June 16, 1960 are the following: P200,000.00 for 1960: P220,000.00 for 1961 and P250,000.00 for 1962. LLphil This revokes BIR Ruling No. 370, series of 1960. Very truly yours, MELECIO R. DOMINGO Commissioner of Internal Revenue