February 2, 1966

The Regional Director
Regional District No. 15
Zamboanga City

S i r :

This is in connection with your letter dated September 24, 1965, to the University of the Philippines, requiring the U.P. Land Grant to file a statement of assets, income & liabilities for the year 1962 by virtue of Republic Act No. 2070, as amended. cdt

It appears that the U.P. Land Grant is a non-corporate enterprise under the administration of the Board of Regents pursuant to Act No. 3608. The owner and operator of the Grant is the University of the Philippines. As the University is a state institution with corporate powers (Sec. 5, Act No. 1870, as amended) discharging governmental functions, it is clearly outside the purview of Section 1 of the Tax Census Law. It may be stated in this connection, that the U.P. is exempt from internal revenue taxes as a governmental instrumentality.

Please be guided accordingly. cdll

Very truly yours,

(SGD.) MISAEL P. VERA
Commissioner of Internal Revenue