Tax Liability of United Realty Corporation

August 20, 1959 BIR RULING NO. 415-59 The President United Realty Corporation 2127 Espaa, Manila S i r : In reply to your letter dated July 23, 1959, I have the honor to inform you that since the United Realty Corporation purchases stocks and other securities for resale, maintaining for the purpose a fixed business establishment, it is considered a dealer in securities pursuant to section 34(t) of the Tax Code. Such being the case, the gains or losses derived by it from the purchase and resale of securities are ordinary and not capital gains or losses, and, therefore, the losses incurred by it from its transactions in securities are considered in full. Very truly yours, (SGD.) MELECIO R. DOMINGO Commissioner of Internal Revenue