BIR Ruling No. 084-63

November 19, 1963 BIR RULING NO. 084-63 The Revenue Collection Agent Carman, Bohol (Thru The Revenue Regional Director Regional District No. 7) Cebu City S i r : Reference is made to your letter dated August 24, 1963, requesting opinion based on the following facts: aisadc "This is with reference to Rep. Act No. 3704 under which operators or owners of rice and corn mills are no longer subject to 2% milling tax, but, instead, to the graduated fixed tax (annual) based on milling capacity per twelve hours. "Under this new law, there are difference administrative schedules assigned to each kind of rice or corn mill and only pure "cone" and kiskisan" types are mentioned. However, I would like to inform you that in this municipality the owners or proprietors of the small ricemills are using a combination of "cone" and the kiskisan" types. First, the palay is placed in the "cone" huller to separate the husk from the grain. Then it passes thru the "kiskisan" to separate the tiki-tiki from the grain." In reply thereto, you are informed that a combination cone kiskisan rice mill operated jointly and involving one continous operation is considered a single machine classified under the higher category, that is cone type. For purposes of the tax, the output of the combination machine constitutes of the total production of the joint operation. If said machines are operated separately, the operator thereof is liable to the fixed tax in an amount corresponding to the capacity of each machine as provided for by the law. Very truly yours, (SGD.) RAMON T. OBEN Acting Commissioner of Internal Revenue