BIR Ruling No. 356-61

September 14, 1961 BIR RULING NO. 356-61 Mr. Sante T. Lim I McKinley Street Tuguegarao, Cagayan S i r : Reference is made to your query as to whether or not a person who in one occasion lends money to a friend to help him in business can be considered a lending investor subject to tax under Section 182(u) of the National Internal Revenue Code. In reply, I have the honor to inform you that to be subject to tax under Section 182(u) of the Tax Code, one must make a practice of lending money for himself or others with interest. A person who merely accommodates a friend and in one occasion lends money with interest does not make a practice of lending money with interest. Accordingly, he is not subject to the fixed tax prescribed in Section 182(u) of the Tax Code. cdti Very truly yours, (SGD.) MELECIO R. DOMINGO Commissioner of Internal Revenue