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June 23, 2009BIR RULING [NSNP-(S30H-069) 385-09]Section 30 (H); 149-95; DA-283-04; S30027-2003 & S30-040-02Angeles Liplin School IncorporatedMabini St., San Nicolas, Angeles CityAttention: Mr. Chua Sin KwokChairman-Board of TrusteeGentlemen :This refers to your letter dated May 6, 2009 requesting for a ruling exempting the Angeles Liplin School Incorporated ("ALSI" for brevity) from payment of taxes. As represented, ALSI is a non-stock, non-profit educational institution with Taxpayer Identification No. 117-049-720. It was incorporated sometime in 1959 with the Securities and Exchange Commission (SEC) under SEC Registration No. 15248. ALSI was given recognition by the Department of Education (DepEd) on June 4, 1998, with Government Recognition No. E-018, Series of 1998, for its pre-elementary course. The primary purpose for which it was incorporated and as reflected in its articles is "to operate and manage an Elementary and High School". The main source of its income are tuition fees.In reply, please be informed that paragraph 3, Section 4, Article XIV of the 1987 Constitution provides viz.:"(3) All revenues and assets of non-stock, non-profit educational institutions use actually, directly and exclusively...