BIR Ruling No. 043-62

February 7, 1962 BIR RULING NO. 043-62 The Regional Director Regional District No. 3 M a n i l a S i r : Reference is made to B.I.R. Ruling No. 36 RO/3 S. of 1961 embodied in the memorandum of the Acting Chief, Legal and Litigation Branch dated July 18, 1961. According to this ruling, the entire sum of P7,000.00 is a deductible professional expense. It appears that Col. Vivencio D. Bayot went to the United States in 1957 under a certain teaching contract with the State College of Washington. For this trip, he allegedly spent the aforesaid sum of P7,400.00 as transportation expenses. Even granting that the aforesaid sum P7,400.00 was actually spent by Col. Vivencio Bayot in going to the United States in order that he can teach at the State College of Washington, still such an expense is not a business expense deductible under Section 30(a)(1) of tract with an employer in a foreign country, without allowance for travel expenses, the expenditure incurred in reaching the place of employment is not a business expense." (Q.D. 45; 2 CB 157 CCh Vol. I. p. 19,017). In view of the foregoing, this Office is of the opinion that the amount of P7,400.00 is not a business expense deductible under section 30(a)(1). The assessment against the aforesaid taxpayer should therefore be revised to conform with the above ruling. cdtech Very truly yours, MELECIO R. DOMINGO Commissioner of Internal Revenue