BIR Ruling No. 090-65

August 12, 1965 BIR RULING NO. 090-65 T. J. Wolff & Co., Inc. P. O. Box 920 M a n i l a Attention : Mr . Apolonio dela Cruz General Manager Gentlemen : This has reference to your letter dated December 29, 1964, requesting a ruling on the rate of percentage tax on the "Rank Xerox 914" office copier which you are contemplating to import. cdt According to the brochure submitted, the machine operates as follows: "The tubular exposure lamps scan the document on the exposure glass, the image of the document is projected thru a mirror-lens-mirror projection system to a constantly rotating cylinder known as the xerographic drum. The xerographic drum has a photoconductive coating which can be given an electrostatic charge. As the drum rotates, it is charged electrostatically and then exposed to the projected image. Exposure of the drum to the image, discharges the static electricity in the areas on the drum which correspond to the white areas of the original document, while the areas which correspond to the dark image remain charged. Developer, consisting of carrier beads and black toner powder, is then cascaded over the exposed area of the drum by the developing unit; the toner powder adheres to the charged areas by electrostatic attraction, thus forming a visible image. A sheet of paper is fed from the supply tray to the drum, where it is brought into contact with the image on the drum and given an electrostatic charge to transfer the image. The sheet of paper, adhering to the drum under electrostatic attraction, is stripped from the drum by an air blast from a series of jets, known as the puffer. (If for some reason the puffer misses the paper, the miss-detector will operate and stop the copier). The drum-cycle is then complete by a high-speed rotating brush which cleans off the residual toner image from the surface of the drum. The paper is carried under a series of heating elements, known as the fuser, the heat from the fuser fuses the image into the surface of the paper, making it a permanent print. The finished copy is then transported to the delivery tray." In answer thereto, I have the honor to inform you that it is the opinion of this Office that the method of copying involved in said "Rank Xerox 914" office copier constitutes photostatic process and, therefore, the machine qualifies as a photostatic machine within the purview of Section 185(j) of the Tax Code subject to the 30% sales tax prescribed therein or to the compensating tax prescribed in Section 190 of the same Code, as the case may be. Very truly yours, (SGD.) BENJAMIN N. TABIOS Acting Commissioner of Internal Revenue