BIR Ruling No. 048-64

July 28, 1964 BIR RULING NO. 048-64 Mr. Dominador M. Sison Acting BIR Collection Agent Binalonan, Pangasinan (Thru the Director, San Fernando, Pampanga) S i r : This refers to your letter dated July 21, 1963 requesting information on whether or not hullers are considered rice mills within the contemplation of Section 182(B)(3)(x) of the Tax Code, as amended by Republic Act No. 3704. In the report of investigation conducted by a Revenue Examiner stationed in Dagupan City, he describes a huller as follows: "In a rice mill, 'kiskisan or Cono', the principal machine is the huller which is run by power furnished by a gasoline or diesel motor engine or an electric motor engine which is then the accessory machine. An ordinary 'kiskisan' huller could be operated y a 16 horse power engine. Where an operator uses a 32 or more horse power engine, he can run two hullers or more at the same time by linking the hullers with link belts attached to an iron rod with several pulleys which is in turn run by the motor or electric engine. . . If the capacity of each huller is around 80 cavanes per twelve hour operation, two hullers operating at the same time can produce 160 cavanes per twelve hour operation. It will be then concluded that the addition of one or more hullers is not a mere device or apparatus to increase the output of the machine itself run simultaneously by one common engine." In reply, you are informed that the mechanical contraption consisting of two or more hullers which are run by a common motor engine is considered a single machine for purposes of Republic Act No. 3704. The entire contraption itself constitutes a rice mill and not each individual huller. Therefore, for purposes of the rate of tax payable by the operator or proprietor of such mechanical contraption, the total milling capacity of all the hullers per twelve hour operation shall be considered and taken into account. Very truly yours, (SGD.) BENJAMIN N. TABIOS Acting Commissioner of Internal Revenue