Taxability of a Person Who Purchases Raw Chestnuts and Resells Them in Cooked Form

October 5, 1966 BIR RULING NO. 040-66 Miss Vicenta Argame 40 K-7th Street Kamias, Quezon City M a d a m : In answer to your letter dated January 18, 1966, I have the honor to inform you that a person who purchases raw chestnuts which he resells in cooked from (roasted or boiled) is considered a manufacturer under Section 194 (x) of the National Internal Revenue Code. As such manufacturer, your client is subject to the P20.00 fixed annual tax (C-14) prescribed in Section 182(A)(1) and to the 7% sales tax provided for in section 186, both of the same Code. cdtech Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue