Purchase of Lumber Surface, Plane or Recut for Purposes of Resale

January 25, 1960 BIR RULING NO. 022-60 Asiatic Lumber Co., Inc. 2037 Juan Luna M a n i l a Gentlemen : Reference is made to your letter dated January 21, 1960 requesting the clarification of the ruling we issued to you on July 27, 1959 (BIR Ruling No. 349) to the effect that, for the purchase of lumber which you surface, plane or recut for the purpose of resale, you are not thereby constituted manufacturers nor contractors. In reply thereto, I have the honor to inform you that our ruling in question finds application whether the recutting, planing or surfacing was made before the sale or at the time of the sale. For instance, if a customer desires a particular size of planed lumber and you do not have the same at the time the purchase is offered, you may recut your available stock to the desired size and plane the same. In such case, you cannot be considered a contractor with respect to the recutting and planing because they are mere incidents of the sale. cdt Very truly yours, MELECIO R. DOMINGO Commissioner of Internal Revenue