BIR Ruling No. 028-83

February 21, 1983 BIR RULING NO. 028-83 Gentlemen : This refers to your letter dated May 19 and July 6, 1982 requesting a ruling as to whether the provisions of Revenue Memorandum Order No. 33-81 can be applied to bank foreclosure sales of real properties before November 19, 1981 when the said Order took effect. It is represented that your bank submitted to the Revenue District Officer of Cabanatuan City its application for the issuance of the appropriate BIR Certification with respect to certain properties located at Cabanatuan City foreclosed by your bank prior to November 19, 1981; and that said Revenue District Officer refused to issue to certification requested on the ground that Revenue Memorandum Order No. 33-81 applies only to bank foreclosures effected after November 19, 1981. In reply, I have the honor to inform you that your query is answered in the affirmative. It should be noted that said Revenue Memorandum Order No. 33-81 does not provide for a cut-off date and that it implements Section 34(h) of the Tax Code, as amended by Batas Pambansa Blg. 37, which took effect on September 7, 1979, so as to provide the procedure in the issuance of certification authorizing the transfer of titles to real property acquired by banks through foreclosure sales. cdtech Very truly yours, (SGD.) RUBEN B. ANCHETA Acting Commissioner Bureau of Internal Revenue