Applicable Taxes to Corn Oil when Extracted from Corn Germ

August 8, 1977 REVENUE MEMORANDUM CIRCULAR NO. 19-77 TO : All Regional Directors, Service Chiefs, Division Chiefs and others concerned It has come to the attention of this Office that there are entities and individuals engaged in the business of purchasing quantities of corn germ for the purpose of extracting crude corn oil therefrom. Corn oil when extracted from corn germ undergoes several stages of physical and chemical processes, before it becomes marketable either as crude corn oil or refined cooking corn oil, hence considered a manufactured product falling under the purview of Section 194(x) of the Tax Code. These entities and individuals are not millers and, therefore, are not to be considered as subject to the annual graduated fixed tax under Section 182 (A)(3)(mm). With respect therefore, to the sales of crude corn oil by said manufacturers, Section 186 of the Tax Code imposing the 7% percentage tax, applies. All previous rulings issued inconsistent with the above should be considered withdrawn and/or revoked. It is desired that this circular be given as wide a publicity as possible. aisa dc EFREN I. PLANA Acting Commissioner of Internal Revenue