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Release of Three (3) Reels of D&G (Cyanamid International) Files

BIR Ruling No. 436-59 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Sep 15, 1959

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September 15, 1959 BIR RULING NO. 436-59 Muller & Phipps (Manila) Ltd. Bonifacio Drive Port Area, Manila Attention : Mr . J . C . Kasten IV, Gen . Manager Gentlemen : This is with reference to your letter dated September 9, 1959, requesting approval for the release of three (3) reels of D&G (Cyanamid International) files without paying the specific tax due thereon for the alleged reason that said films are educational films. cd The D&G films, in question, are briefly described as follows: (a) Cs-20 "OPERATING ROOM SUTURE TECHNIQUE" One print 976 ft. color with sound; time 28 minutes (b) CS-209 "CORRECTION OF CLEFT LIP" One print 742 ft. (c) CS-240 "END-TO-END ANASTOMOSIS OF ESOPHAGUS FOR CONGENITAL ATRESIA WITH TRACHEO-ESOPHAGEAL FISTULA" One print 1087 ft. color with sound; time 30 minutes. Our records show, however, that the above-mentioned films with a total length of 2,805 feet are to be used for advertising the products of "Muller & Phipps" sold in the Philippines. It is, therefore, evident that the intention of importing said films to the Philippines is for advertising purposes. In view of the foregoing reasons, I regret to inform you that your request for authority to release the D&G films aforementioned without paying the specific tax due thereon has to be, as it is hereby, denied. This letter will serve as authority for the Collector of Customs, Manila, to release the above-mentioned D&G films upon payment of the specific tax due thereon in accordance with section 146, in relations to section 125, of the Tax Code, as amended. cdll Very truly yours, (SGD.) MELECIO R. DOMINGO Commissioner of Internal Revenue

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