Lease on the Use of Clean Baby Underwears and Diapers

May 6, 1959 BIR RULING NO. 223-59 Joaquin S. Asuncion & Co. Certified Public Accountants R-206 Araneta Bldg. 353 Nueva, Manila Gentlemen : Reference is made to your letter dated May 2, 1959 stating the following: "Our client is a Filipino corporation engaged in the business of leasing the use of clean baby underwears and diapers to the public for a price. It retained the legal title over these leased clothes and delivers the soiled clothes to another corporation for washing and cleaning. Our client is not in the laundry business as it pays a steam laundry for such services, just like any other customer of the laundry company. The income from the rent of these baby underwears and diapers is its principal source of revenue, for the present." You now request information as to the business or occupation tax liability of your client. In reply thereto, I have the honor to inform you that your client under the circumstances quoted above is not subject to any internal revenue business or occupation tax. cdta Very truly yours, (SGD.) JOSE ARAAS Commissioner of Internal Revenue