Non-deductibility of a Destruction of a Residential House by White Ants (anay)
BIR Ruling No. 319-60 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Jul 26, 1960
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July 26, 1960 BIR RULING NO. 319-60 Mr. John D. Young P. O. Box No. 233 Cebu City S i r : In reply to your letter dated March 22, 1960, I have the honor to inform you that the destruction of a residential house by white ants (anay) is not deductible under section 30(d)(1)(C) of the Tax Code for the reason that the word "casualty" denotes an "accident, a mishap, some sudden invasion by a hostile agency, and excluded the progressive deterioration of property through a steadily operating cause". (U.S. vs. Rogers 9 Cir., 120 F. 2d 244; Fay et al vs. Helvering 120 F (29) 253 27 AFTR 432). casia Very truly yours, (SGD.) MELECIO R. DOMINGO Commissioner of Internal Revenue
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