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May 26, 2010BIR RULING [DA-(DT-011) 076-10]Section 101 (A) (2); BIR Ruling No. 003-01Office of the Solicitor General OSG Building, 134 Amorsolo StreetLegaspi Village, Makati CityAttention: Karl B. MirandaAssistant Solicitor General Gentlemen :This refers to your letter dated November 24, 2009 requesting the exemption of a donation of real property in favor of the Philippine Tourism Authority (PTA), now succeeded by the Tourism Infrastructure and Enterprise Zone Authority (TIEZA) from donor's tax. Documents submitted to this Office show that on October 13, 2000, a Deed of Donation over a five-hectare parcel of land located in Barrio Indahag, Cagayan de Oro City, was executed by Suzette Magtajas-Daba and Anita G. Magtajas, both residents of Cagayan City, in favor of the PTA. PTA is an attached agency of the Department of Tourism created under Presidential Decree (PD) No. 564 mandated to implement certain tourism projects.Under the terms of the Deed of Donation, the said five-hectare parcel of land is to be taken from Magtaja-Daba's 47,872-square meter parcel of land and Magtajas' 42,242-square meter parcel of land. The donated...