BIR Ruling No. 058-63

August 9, 1963 BIR RULING NO. 058-63 2nd Indorsement Returned to the Regional Director, BIR Regional District No. 3, Manila, the papers pertaining to the case of the Doctors Blood Bank, 928 Gonzales St., Ermita, Manila. llcd This Office believes that the collection, processing and sale of human blood does not constitute the doing of business but rather the exercise of a profession. It is to be noted that under Section 6, Administrative Order No. 56, s. of 1959, of the Department of Health, only licensed physicians duly registered with the Board of Medical Examiners who have had at least three years of actual experience and/or training in blood bank operations are permitted to establish or operate a blood bank. Besides, human blood cannot be considered objects of commerce of man. The collection, processing, and preservation of human blood may, therefore, properly be considered as an exercise of the medical profession. (SGD.) JOSE B. LINGAD Acting Commissioner of Internal Revenue The above ruling was duly signed by the Acting Commissioner of Internal Revenue on August 9, 1963. LibLex (SGD.) P. F. LANDAS Revenue Operations Head (Legal)