BIR Ruling No. 037-65

May 13, 1965 BIR RULING NO. 037-65 Messrs. Carlos J. Valdes & Co. Certified Public Accountants 1130 Perez Street Paco, Manila Gentlemen : This refers to your letter dated October 31, 1964 requesting opinion on the following: lexlib "1. A company buys flitches, cuts them into standard sizes, trims and kiln dries the same, and then sells them to the public; "2. A company buys already manufactured lumber, recuts the same into different standard sizes, trims and kiln dries the same, and then sells such lumber to the public." In reply thereto, I have the honor to inform you as follows: Flitches are still timber. Therefore, he who buys flitches for the purpose of saving them into lumber of standard sizes is a manufacturer subject to the fixed and percentage taxes prescribed by Sections 182(A)(1) and 186 of the Tax Code. He who buys already manufactured lumber for the purpose of recutting them into standard sizes of kiln-drying them preparatory to the resale thereof is a mere dealer subject to the graduated annual fixed tax imposed by Section 182(A)(2) of the same Code. Very truly yours, (SGD.) BENJAMIN N. TABIOS Acting Commissioner of Internal Revenue