In view of the foregoing, your request is hereby denied. You are, therefore, requested to pay the...

August 28, 1958 BIR RULING NO. 470-58 Mr. Mauro M. Miranda Office of the Comptroller University of the Philippines S i r : With reference to your letter dated July 24, 1958 wherein you requested for the reconsideration of the imposition of a compromise penalty of P10.00 in extrajudicial settlement of the penal liability arising from your failure to attach to your 1953 income tax return, have yearly statement of net worth and operations, I have the honor to inform you as follows: cdt All persons subject to internal revenue tax whose gross quarterly sales, earnings, receipts, or output do not exceed P5,000 are required to file with their income tax return the yearly statement of net worth and operations, pursuant to Revenue Regulations No. V-13. Failure to comply with the said requirement constitutes a violation penalized under Section 352 of the Tax Code. Since your gross quarterly earnings do not exceed P5,000, you are subject to the aforesaid requirement. Your failure, therefore, to comply therewith is a violation of the aforesaid regulation which may be extrajudicially settled. The circular and law cited by you in support of your contention that you are not required to file the early statement of net worth and operations are not in point because while you are not liable to the real estate dealer's fixed tax, nevertheless, for purposes of the requirement it is enough that you are subject to any internal revenue tax. As you are subject to the income tax, you are covered thereby. It may be stated in this connection, however, that, if your only source of income is your salary, you are not required to file the said statement. In view of the foregoing, your request is hereby denied. You are, therefore, requested to pay the suggested compromise penalty of P10.00 in order that your case may be closed. Very truly yours, (SGD.) MELECIO R. DOMINGO Acting Commissioner of Internal Revenue