Taxability of a Person Engaged in a Baby Dress Business

March 30, 1960 BIR RULING NO. 162-60 Mrs. Purificacion David c/o Sy Tong Gasoline Station Gen. Hison St. San Fernando, Pampanga M a d a m : In your letter date March 30, 1960, you requested information as to the taxability of the business described by you as follows: "We wish to inform you that I am a contractor of Philippine American Embroideries, Inc. at Paraaque, Rizal in the baby dress business. "In this connection I used to get dozens of dress from the Company with the fixed price per dozen. Then this dress I used to give to may worker, the expenses of which should be little less or below the price fixed by the Company. As for example, if I get a dozen for P2.50 from the Company then I should have this dozen to be issued to may worker of P2.15 or P2.20 in this case I will earn either P0.30 or P0.35." Under the foregoing facts, I have the honor to inform you that you are not subject to any internal revenue business tax, pursuant to section 191 of the Tax Code, as amended by Republic Act No. 2072. However, the income derived from such transaction is subject to income and residence taxes. Very truly yours, MELECIO R. DOMINGO Commissioner of Internal Revenue