Return of the Amount of Rentals Received by Mr. Bernia

January 29, 1958 BIR RULING NO. 070-58 6th Indorsement Respectfully returned to the Regional Director, Regional District No. 2, San Fernando, Pampanga, the herein papers bearing on the tax case of Mr. Tomas Bernia of Floridablanca, Pampanga. LexLib There is no question as to the amount of rentals received by Mr. Bernia for the crop years 1950-1953 because said rentals were paid in money as certified to by the Pampanga Sugar Mills. However, inasmuch as during the crop years 1953-54 and 1954-55 the rentals paid to Mr. Bernia were in the form of quedans, there is transmitted herewith the price quotations for sugar and molasses for said years furnished by the Director of Commerce. Said price quotations should be used in computing the rentals received by Mr. Bernia during the crop years in question. As will be noted, the price quotations for sugar varies according to kind, in view of which, inquiry should be made for the purpose of ascertaining the kind of sugar given as rentals to Mr. Bernia. In this connection, he is advised that the lease of sugar quota does not come within the purview of Section 3 of Commonwealth Act No. 567. If, therefore, the lease in question covers both sugarland and sugar quota, only the rental corresponding to the sugarland should be considered in the computation of the tax. Mr. Bernia has been advised of the return thereof. aisadc (SGD.) JOSE ARAAS Commissioner of Internal Revenue