Tax Exemption Granted to Abellana National Vocational School Retail Store

July 20, 1960 BIR RULING NO. 324-60 5th Indorsement Returned to the Regional Director, BIR Regional District No. 7, Cebu City, the herein papers bearing on the request of the Abellana National Vocational School Retail Store for exemption from internal revenue taxes, with the following comment. It appears that the retail store is financed and operated by the above-mentioned school; that the school is under the supervision of the Bureau of Public School and presumably maintained and financed by the National Government; that it is used as a workshop of the "Retail Merchandizing" students; that it is "catering exclusively to the students" of the same school; that a certain margin of profit is added to the cost price of the goods, such as school supplies, cakes and soft drinks, just enough to cover operating and maintenance expenses of the store; and that the accounting of funds of said school is subject to the examination of the City Auditor's representative. Based on the foregoing facts, said store is undoubtedly not subject to any internal revenue taxes for the reason that the said school is operated and maintained by the National Government itself, that it is not engaged in business for profit, and that no amount of the profit, if there is any, goes to the benefit of any individual but solely to the school itself. Accordingly, the required registration of the store's invoices and books of accounts with the Bureau of Internal Revenue is no longer necessary. Premises considered, the request of said school for tax exemption has to be, as it is hereby, granted. cdt (SGD.) MELECIO R. DOMINGO Commissioner of Internal Revenue