Application for the Issuance of Certificate of Indebtedness

February 12, 1959 BIR RULING NO. 062-59 Mr. Luis F. Cabinete Attorney at Law 1816 Azcarraga, Manila S i r : With reference to your application for the Issuance of Certificate of Indebtedness, dated February 10, 1959, I have the honor to inform you that pursuant to Section 2 of Republic Act No. 304, the issuance of a certificate of indebtedness is subject to the limitation that the face value thereof shall not exceed the amount which the applicant needs for the payment of taxes to which he is directly liable. As the estate and inheritance taxes due on the estate involved in Special Proceedings No. 71805 before the Court of First Instance of Manila are the direct liability of Marcela de Mesa, notwithstanding the fact that upon her failure to pay said taxes you became liable therefor as surety, this Office regrets that it cannot accept in payment of those taxes, the certificate of indebtedness you are contemplating to apply for. In view thereof, said application is herewith returned to you unsigned on the space provided for the signature of the creditor. It will be highly appreciated if you can now settle your liability in cash. Very truly yours, (SGD.) JOSE ARAAS Commissioner of Internal Revenue