BIR Ruling No. 024-61

February 1, 1961 BIR RULING NO. 024-61 This is with reference to your letter . . ., in connection with B.I.R. Ruling No. 11, Series 1961. cdtech It appears that you committed a minor error in the presentation of the facts in your first query dated January 20, 1961, which facts were used as the basis of our ruling Numbered 11, above-mentioned. You stated that you used the words "pound instead of the words "ounce" or "ounces" in your statement of facts. In view of said correction, you now submit the following facts as the basis of a new ruling by this Office, to wit: "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 1/8 ounce, ounce, ounce, 1 ounce, and 2 ounces and placed in locally purchased and 2 ounces 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 1/8 ounce, ounce, ounce, 1 ounce, and 2 ounces, respectively, there is no other raw materials 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 1/8 ounce, ounce, ounce, 1 ounce and 2 ounces in boxes when resold at wholesale to drugstores." Based on the foregoing facts as presented, please be informed that your client "X" is still considered a repacker of a locally purchased cotton, subject to the graduated annual fixed tax (C-13) prescribed in Section 182(A)(2) of the Tax Code, as amended. Furthermore, your client is subject to the income and residence taxes prescribed by law. LexLib