Payment of the Occupation Tax of the Nursing Staff of the Sacred Heart Hospital, Southwestern University

April 6, 1960 BIR RULING NO. 174-60 The Director Sacred Heart Hospital Southwestern University Cebu City S i r : Reference is made to your letter dated September 8, 1959, requesting for exemption from the payment of the occupation tax of the nursing staff of the Sacred Heart Hospital, Southwestern University, Cebu City. Investigation disclosed that the Sacred Heart Hospital is owned and operated by the Southwestern University and is conducted for private gain. It is shown further that is a training center of the students of the College of Medicine and school of Nursing of that University and that the nurses render their professional services exclusively to the hospital for charity patients. Under the foregoing circumstances, I have the honor to inform you that registered nurses employed in a hospital operated by a private entity, conducted for private gain are not covered within the purview of the exemption provided for by Section 182(c)(7) of the Tax Code. They are, therefore, subject to the occupation tax in the amount of P50.00 each prescribed under Section 182(B)(2) of the same Code. cdta Very truly yours, (SGD.) MELECIO R. DOMINGO Commissioner of Internal Revenue