BIR Ruling No. 047-63

May 29, 1963 BIR RULING NO. 047-63 The Regional Director BIR Regional District No. 9 Zamboanga City S i r : In connection with the inquiry of Examiner Pedro C. Sales of the Provincial Revenue Office, Pagadian Zamboanga del Sur, which you referred to this Office under 3rd Indorsement dated April 22, 1963, you are informed that proprietors or operators of motorized tricycles are considered transportation contractor subject to the 2% tax prescribed by Section 192 of the Tax Code. LLphil By taxing a business or occupation, it is by no means meant to authorize such business or occupation contrary to local laws. The internal revenue law "only intends to authorized it to be carried on" (In re Gomingoe, 96 Fed. Rep., 561, cited in Araas' annotations & Jurisprudence on the National Internal Revenue Code, as amended, Vol. 11 p. 69; Section 179, Tax Code.) The observations, therefore, of Examiner Sales are not of any moment. Very truly yours, (SGD.) JOSE B. LINGAD Acting Commissioner of Internal Revenue The above ruling was duly signed by the Acting Commissioner of Internal Revenue on May 29, 1963. LLjur (SGD.) P. F. LANDAS Revenue Operation Head (Legal)