BIR Ruling No. 075-62

May 25, 1962 BIR RULING NO. 075-62 Mr. Bernabe C. Santiago 2125 Vision, Sta. Cruz M a n i l a S i r : Reference is made to your letter of the 12th instant, requesting a ruling on the following facts: "(1) Mr. A owns a fleet of three fishing boats. He provides these boats with fuel, ice, provisions, spare parts and other necessities for about a month's trip to Palawan and other fishing grounds. On the way a boat picks up a team of fishermen who have their own bancas, nets and provisions. The fishermen catch the fish and Mr. A buys them. This buying of fish is called "Fish Purchases" in Mr. A's books of account. When there is enough fish loaded on board, the boat returns to Manila and the fish is sold wholesale. Mr. A secured at the beginning of the year a PTR C-14. "(2) Mr. B owns some houses and apartments for rent. In one of his apartments he installed some beds and rents these bed spaces to students. He serves so meals. The students order their meals for some nearby restaurants. Mr. B pays a PTR C-8. Are the rental income of this dormitory or bed spaces subject to another tax or taxes?" In answer thereto, I have the honor to inform you that, based on the aforequoted facts. "A" is a dealer of locally purchased fish and, therefore, subject to the graduated annual fixed tax (C-13) prescribed in section 182(A)(2) of the Tax Code. Accordingly, "A" should not have secured a C-14 privilege tax receipt. The rental income received from said bed spaces is not subject to any business or occupation tax. Very truly yours, JOSE B. LINGAD Commissioner of Internal Revenue