COMPILED NOTES: SABABAN, MAMALATEO & CHAVEZ

MARIVIC B. DE GRACIA
TAXATION 2

MARIVIC DE GRACIA

TRANSFER TAX 15%-relative

30%-stranger
-refers to the burden imposed upon the right to gratuitously transfer Filing: within 6 months Filing: within 30 days
or transmit property, tangible or intangible from one person to from the date of death from the date of
another. donation

-are taxes imposed upon the gratuitous disposition of private

property. ESTATE TAX

KINDS OF TRANSFER TAXES: FORMULA:

ESTATE TAX DONOR’S TAX TAX ON THE Gross Estate (Sec. 85)
TRANSFER OF Less: Ordinary Deductions (Sec. 86)_____________
REAL
PROPERTY Equals: Net Estate before share of surviving spouse
NIRC NIRC LGC Less: Share of surviving spouse________________
Donation mortis causa Donation inter vivos
Equals: Net estate before special deductions
Tax levied on the Tax levied on the
transmission of transmission of Less: Special deductions______________________
properties from properties from a
Equals: Net taxable estate
decedent to his heirs living person to
another living person. Multiply:Tax Rate (Sec 84)______________________
Tax on the privilege to
Equals: Estate Tax Payable
transmit property at
death
Excise tax or privilege Excise tax or If there’s tax credit available:
tax privilege tax
Effective upon death Effective during the Estate tax payable
life time of the donor Less: Tax credit____________
Tax base is the net Tax base is the net Equals: Final estate tax payable
estate gift within the
calendar year
Net estate amounting Net gift amounting to LAW GOVERNING THE IMPOSITION OF ESTATE TAX
to P200,000 is P100,000 is
exempted exempted -statute in force at the time of death of the decedent governs.
20% highest rate highest rates:

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 COMPILED NOTES: SABABAN, MAMALATEO & CHAVEZ
MARIVIC B. DE GRACIA
TAXATION 2

MARIVIC DE GRACIA
GROSS ESTATE TWO FACTORS AFFECTING THE COMPOSITION OF THE GROSS
ESTATE:
-all properties and interests in properties of the decedent at the time of his
death shall be included in his gross estate. 1. Citizenship and residence of the decedent at the time of death
2. Location of the property, whether within or without the Philippines.
-the properties included in the gross estate of the decedent would depend
on whether or not the decedent is a citizen or alien and whether or not the
alien decedent is a resident of the Philippines at the time of his death.

-RCD, NRCD, RAD, NRAD are subject to estate tax

IMMOVABLE AND
INTANGIBLE
TANGIBLE
PERSONAL
PERSONAL
PROPERTY
PROPERTY
WITHIN WITHOUT WITHIN WITHOUT
RCD
RAD    
NRCD
NRAD  -  -
NRAD WITH  - - -
1
RECIPROCITY

1
RECIPROCITY- in order to prevent multiplicity of taxation, the tax code provides
that the tax imposed by this title shall be credited with the amounts of any estate
tax imposed by the authority of a foreign country.

NO TAX SHALL BE IMPOSED IN RESPECT OF INTANGIBLE PERSONAL

PROPERTY OF CITIZEN AND RESIDENT OF A FOREIGN:

a. No transfer tax clause- when the foreign country does not impose transfer tax
of any character in respect of intangible personal property of citizens of the
Philippines not residing in that foreign country, or
b. Exemption clause- when the foreign country imposes transfer taxes but grants
similar exemption from transfer taxes in respect of intangible personal property
owned by citizens of the Philippines not residing in that foreign country.

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 COMPILED NOTES: SABABAN, MAMALATEO & CHAVEZ
MARIVIC B. DE GRACIA
TAXATION 2

MARIVIC DE GRACIA
COMPOSITION OF DECEDENT’S GROSS ESTATE

TRANSFER IN CONTEMPLATION OF PROPERTY PASSING UNDER GENERAL

DECEDENT’S INTEREST
Kinds:
1. Property owned- decedent
possesses all the attributes of
ownership.
2. Interest in property
possessed- interests accrued
in favour of the decedent at the
time of his death. (accrued
income)
Example:
a. dividends declared by a
corporation before death of the
stockholder although paid after
death
b. partnership profits even if
paid after death of the partner
c. proceeds of a life insurance
policy payable to a designated
revocable beneficiary
d. right of usufruct
3. Property or interest
transferred.
DEATH
-does not refer to the GENERAL
EXPECTATION OF DEATH but to the
THOUGHT OF DEATH, as a controlling
motive which induces the disposition of
the property for the purpose of avoiding
tax.
Kinds:
1. By trust or otherwise, in contemplation
of or intended to take effect in
possession or enjoyment at or after
death.
2. By trust or otherwise, under which he
has retained for his life or for any period
which does not in fact end before his
death:
a. the possession or enjoyment of, or the
right to the income from the property, or
b. the right, either alone or in conjunction
with any person, to designate the person
who shall possess or enjoy the property
or the income therefrom.
Exception:
The transfer is a bona fide sale for an
adequate and full consideration in money
or money’s worth
Circumstances taken into account:
a. age and state of health of the
decedent at the time of gift
b. length of time between the gift and the
date of death (short interval)
c. concurrent making of a will
REVOCABLE TRANSFER
-transfer made by the decedent
during his lifetime but the use,
enjoyment and possession
thereof is subject to his power
to alter, amend, revoke or
terminate at the time of his
death.
-the decedent retains
tremendous power and control
over the property
Exception:
In case of bona fide sale for an
adequate and full consideration
in money or money’s worth
POWER OF APPOINTMENT
POWER OF APPOINTMENT
-refers to a right to designate the person or
persons who shall enjoy or possess certain
property from the estate of a prior decedent
a. GENERAL- when it gives to the donee
the power to appoint any person he
pleases, including himself, his spouse, his
estate, executor or administrator, and his
creditor, thus having as full dominion over
the property as though he owned it.
b. SPECIAL- when the done can appoint
only among a restricted or designated class
of persons other than himself.
Rationale:
The property passing under a general
power of appointment comes from the
donor and the donee-decedent.
The power to dispose of property at death
by the exercise of a power of appointment
is the equivalent of ownership. It is a
potential source of wealth to the appointee.
Note: to determine whether included in
estate or not, know who has the choice to
nd
designate the 2 heir, if the
transferor/donor instructs the
transferee/donee/recipient/decedent that he
can transfer the property to whomever he
wants included in the gross estate of the
latter at the time of his death.

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 COMPILED NOTES: SABABAN, MAMALATEO & CHAVEZ
MARIVIC B. DE GRACIA
TAXATION 2

MARIVIC DE GRACIA

COMPOSITION OF DECEDENT’S GROSS ESTATE

TRANSFER FOR INSUFFICIENT

PROCEEDS OF LIFE INSURANCE PRIOR INTEREST
CONSIDERATION
-depend on the designated beneficiary, the manner of -applies to the transfer, trust, estates, -applied when the transfer was made due to an
designation whether revocable or irrevocable, and the interest, rights, powers and relinquishment impending death, say, due to a terminal illness.
period and source of the funds used in paying the of powers either as:
premiums. Exception:
1. transfer in contemplation of death Bona fide sale for an adequate and full
Beneficiary: 2. revocable transfer, and consideration in money or money’s worth
1. Estate- included in the Gross Estate whether revocable 3. proceeds of life insurance
or not. Requisites:
2. Other than the decedent’s estate, executor or 1. the transfer is either:
administrator- included in gross estate if revocable a. in contemplation of death
b. revocable transfer, or
Insurance proceeds are presumed to be revocable, c. property passing under a general
absence of express stipulation of its irrevocability. power of appointment

Policy taken before marriage- source of funds 2. consideration received is less than the FMV
determines ownership of the proceeds at the time of transfer

Policy taken during marriage- 3. the difference between the FMV at the time
a. beneficiary is the estate- proceeds are conjugal (1/2 of death and consideration shall be included in
share of spouse not taxable) the gross estate of the decedent.
b.beneficiary is other than estate- proceeds are payable
to the beneficiary even if paid out of the conjugal FMVT P1M P1M
partnership FMVD 500K 1.5M
CONSIDERATION 300K 1M
Not taxable: INCLUDED GE 200K 0
a. accident insurance proceeds
b. group insurance policy taken out by a company for its Procedure:
employees 1.Compare the FMVT and the FMVD
c. amount receivable by any beneficiary irrevocably 2. if the FMVT is greater, determine between
d. proceeds of insurance issued by GSIS to government the FMVD and consideration received.
officials and employees and benefits under SSS 3. the difference-included in the GE
e. proceeds payable to heirs of deceased members of
military personnel.

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 COMPILED NOTES: SABABAN, MAMALATEO & CHAVEZ
MARIVIC B. DE GRACIA
TAXATION 2

MARIVIC DE GRACIA

2
THE FF. INTANGIBLE PERSONAL PROPERTIES HAVE SITUS IN VALUATION OF THE PROPERTY
THE PHILIPPINES:
REAL
PERSONA USUFRUCT
1. Franchise which must be exercised in the Philippines; L PROP.
PROPERTY SHARES OF STOCKS
SEC. 88(A)
2. Shares, obligations, or bonds issued by any corporation organized or (SEC. 88 B)
FMV at FMV at the LISTED -taken into
constituted in the Philippines in accordance with its laws; UNLISTED
the time time of death SHARES account the
3. Shares, obligations, or bonds issued by any foreign corporation 85% of SHARES
of death (PSE) probable life of
the business of which is located in the Philippines; appraised common FMV= the beneficiary
4. Shares, obligations, or bonds issued by any foreign corporation if such value of real shares: arithmetic in accordance
shares, obligations or bonds have acquired a business situs in the property as of Book mean with the latest
Philippines; the time of Value between BASIC
death shall be, the highest STANDARD
5. Shares or rights in partnership, business or industry established in the
WHICHEVER preferred and lowest MORTALITY
Philippines. shares: at quotation
IS HIGHER of: TABLE,
a. FMV par value at a date approved by
EXEMPTION OF CERTAIN ACQUISITIONS AND TRANSMISSIONS, nearest the
determined by Sec. of Finance,
the ff shall NOT be taxed: (SEC. 87) the date of upon
commissioner death if recommendatio
a. the merger of usufruct in the owner of the naked title; b. FMV fixed none is n of the
b. The transmission or delivery of the inheritance or legacy by the by the available Insurance
fiduciary heir or legatee to the fideicommissary; provincial or on the date Commissioner.
c. The transmission from the first heir, legatee or done in favour of city assessors of death
another beneficiary, in accordance with the desire of the predecessor;
d. All bequest, devise, legacies, or transfer to social welfare, cultural and
charitable institutions no part of the net income of which insures to the Q: Is there a conflict between sec. 87a and sec 88a because under sec.
benefit of any individual: provided, however, that not more than 30% shall 88A, the value of the usufruct is determined in order to be included in the
be used institution for administrative purposes. GE, while SEC.87A, upon the death of the usufructuary, the merger of the
e. bequest to be used actually, directly, and exclusive for educational usufruct to the naked owner is exempt from that estate?
purposes.
A: NONE. Under Sec 87A, the usufruct referred to is one without a fixed
f. Exemptions under reciprocity clause.
period such that upon the death of the usufructuary, the usufruct is
g. Exemptions under special laws.
extinguished. On the other hand, Sec 88A contemplates a situation where
the usufruct is for a fixed period such that upon the death of the
usufructuary, the usufruct forms part of the estate since the period is not
2
Principle of mobile sequuntur personal- refers to the principle that taxation of yet lapsed. Hence, it is material to determine the value of such usufruct.
intangible personal property generally follows the residence or domicile of the
owner thereof.

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 COMPILED NOTES: SABABAN, MAMALATEO & CHAVEZ
MARIVIC B. DE GRACIA
TAXATION 2

MARIVIC DE GRACIA

RCD, RAD, NRAD

ALLOWABLE DEDUCTIONS NRCD (Sec. 86 B)
(Sec 86 A)
ORDINARY DEDUCTIONS (RR 2-2003)
1. Expenses, losses, indebtedness, taxes and etc. (ELITE) (Sec 86 A)  

a. Funeral expenses (Sec 86 A1a)

-amounts for actual funeral expenses or in an amount equal to 5% of the GE, whichever is LOWER, but in NO CASE
to exceed P200k shall be deducted to GE.

b. Judicial expenses (Sec 86 A1b)

-expenses incurred in the testamentary or intestate proceedings for the settlement of the estate
-expenses must be essential to the proper settlement of the estate
Note: Extrajudicial expenses shall be allowed as deductions from the gross estate provided that these are incurred for
the settlement of the estate of the deceased. (Pajonar v. CIR)

c. Claims Against the Estate (Sec 86 A1c)

-the decedent is the DEBTOR
Requisites:
the amount of indebtedness must be included in the GE.
the debt instrument or the contract of loan must be notarized at the time of indebtedness was incurred.
if the loan was contracted within 3 yrs. Before the death of the decedent, the administrator or executor shall
submit a statement showing the disposition of the proceeds of the loan; and
a duly notarized certification as to the unpaid balance of the debt from the creditor, if the creditor is a
corporation, such sworn certification shall be signed by the president, or Vice President, or other principal
officer of the corporation.
Note:
- An indebtedness that has been condoned or has prescribed may not be claimed as deduction.
-Unpaid taxes that accrued after the death of the decedent are not deductible from gross estate, they are properly
chargeable to the income of the estate.

d. Claims Against Insolvent Persons (Sec 86 A1d)

-the decedent is the CREDITOR
Requisite:
the amount of the claims has been initially included as part of the gross estate of the decedent; and
incapacity of the debtors to pay their obligations is proven, not merely alleged.

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 COMPILED NOTES: SABABAN, MAMALATEO & CHAVEZ
MARIVIC B. DE GRACIA
TAXATION 2

MARIVIC DE GRACIA

e. Unpaid mortgages, taxes and casualty losses (Sec 86 A1e)

3 Expenses:

i. mortgage indebtedness
-the decedent is the mortgagor-debtor
-limited to the extent that they were contracted bona fide and for an adequate and full consideration in money or
money’s worth
-The value of the property mortgaged must be included as part of the gross estate

ii. taxes which accrued before the death of the decedent

-taxes accrued prior to the death of the decedent
Note: estate tax is not included under this section since it only accrues upon the death of the decedent

iii. loss by virtue of natural calamity

-fires, storms, shipwrecks, or other casualties, or from robbery, theft or embezzlement

Requisites:
Losses are not compensated for by insurance
At the time of the filing of the return, such losses have not been claimed as a deduction for income tax
purposes
Such losses were incurred not later than the last day for the payment of the estate tax (6 months after the
death of the decedent)

2. Property Previously Taxed (PPT) or Vanishing deductions (Sec 86)  

-applicable to both estate and donor’s tax
-refers to property which forms part of the gross estate situated in the Philippines of any person died within 5 years
prior to his death.
-operates to ease the harshness of successive taxation of the same property within a relatively short period of time
upto 5 years, occasioned by the untimely death of the transferee after the death of the prior decedent-donor
Requisites:
the property situated in the Philippines must be part of the gross estate of the present decedent-donee
the present decedent-donee must have died within 5 yrs prior to the death of the prior decedent-donor or the
property was transferred by donation to the present decedent-donee within 5 years to his death
the estate tax or donor’s tax must have been paid on the property transferred
such property can be identified as having been received by the present decedent-donee from the prior
decedent-donor by gift, or inheritance
no previous vanishing deduction on the property given the value of the net estate of the prior decedent-donor.

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 COMPILED NOTES: SABABAN, MAMALATEO & CHAVEZ
MARIVIC B. DE GRACIA
TAXATION 2

MARIVIC DE GRACIA

Percentage:
i. if the prior decedent died within 1 year prior to the death of the present decedent-100%
ii. more than 1 year but not more than 2 years- 80%
iii. more than 2 years but not more than 3 years- 60%
iv. more that 3 years but not more than 4 years- 40%
v. more than 4 years but not more than 5 years- 20%

3. Transfer for public use (Sec 86)  

-for the use of the Government, or any political subdivision thereof shall be considered as deduction from the gross
estate
-allowed as a deduction is that the bequest, devise or property transferred should be used exclusively for public
purposes.
RCD, RAD, NRAD
NRCD (Sec. 86 B,
SPECIAL DEDUCTIONS (RR 2-2003) (Sec 86 A, NIRC)
NIRC)
1. The family home (Sec 86)  -
-means the dwelling house, including the land on which it is situated, where the husband and wife, or a head of the
family, and members of their family resides, as certified to by the Brgy. Captain of the locality.

Conditions for allowance of family home as deduction from the gross estate:
i. the family home must be the actual residential home of the decedent and his family at the time of his death, as
certified by the brgy. Captain of the locality where the family home is situated;
ii. the total value of the family home must be included as part of the gross estate of the decedent; and
iii. allowable deduction must be in an amount equivalent to the current FMV of the family home as declared or included
in the gross estate or the extent of the decedent’s interest, whichever is lower, but not exceeding P1,000,000.

2. Standard Deduction (Sec 86)  -

-the deduction is automatic without need for substantiation
-P1,000,000.00
3. Medical Expenses (Sec 86)  -

Requisites:
all medical expenses incurred within 1 year prior to the death of the decedent
must be duly substantiated with official receipts
total amount must not exceed P500,000

Note: medical expenses in excess of P500,000 shall no longer be allowed as deduction

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 COMPILED NOTES: SABABAN, MAMALATEO & CHAVEZ
MARIVIC B. DE GRACIA
TAXATION 2

MARIVIC DE GRACIA

4. Benefits under R.A. 4917  -

-amount received by the heirs of decedent-employee PROVIDED that such amount is included in the gross estate of
the decedent employee.

Requisites provided in RA 4917:

The decedent-employee has been employed for at least 10 years
Must not be less than 50 years old at the time of retirement
The benefit can be availed only once
the benefits granted must be in accordance with a reasonable private benefit plan maintained bu the employer
duly approved by the BIR.
5. Share of the surviving spouse (Sec 86)  
-the capital of the surviving spouse of a decedent shall not be deemed a part of the decedent’s gross estate
-applicable only to spouse legally married

MISCELLANEOUS PROVISION (SEC. 86 D)

NRA- no deduction shall be allowed UNLESS the executor, administrator or heirs includes in the estate tax return of the decedent the value at
the time of death, that part of the gross estate of the non-resident not situated in the Philippines.

Even if a NRA is taxable only for properties situated in the Philippines, for purposes of the estate tax return, ALL PROPERTIES
WHETHER SITUATED IN THE PHILIPPINES OR OUTSIDE SHALL BE INCLUDED IN THE RETURN.

-Failure to comply with this requirement, the estate of NRA shall not be allowed to claim any deduction.

ESTATE TAX TABLE

OF THE EXCESS
OVER BUT NOT OVER TAX PAYABLE PLUS
OVER
P200,000 EXEMPT - P200,000
P200,000 P500,000 P0 5% P500,000
500,000 2,000,000 15,000 8% 2,000,000
2,000,000 5,000,000 135,000 11% 5,000,000
5,000,000 10,000,000 465,000 15% 10,000,000
10,000,000 AND OVER 1,215,000 20% 10,000,000

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 COMPILED NOTES: SABABAN, MAMALATEO & CHAVEZ
MARIVIC B. DE GRACIA
TAXATION 2

MARIVIC DE GRACIA

NOTICE OF DEATH (SEC. 89) -Who will file:

-Filing of notice of death in cases of: Executor;

Administrator; or
Transfer subject to tax Any of the legal heirs
Where though exempt, the gross value of the estate
exceeds P20,000 -The return must be under oath in duplicate setting forth:

-Who will file: Value of the GE of the decedent at the time of his death (NRAD
only GE situated in the Philippines)
Executor; Deductions allowed from GE
Administrator; or Ascertainable and supplemental data as may be necessary to
Any of the legal heirs establish the correct taxes.

-Time of filing: *ESTATE TAX RETURNS SHOWING A GROSS VALUE EXCEEDING

P2,000,000 SHALL BE SUPPORTED WITH A STATEMENT DULY
Within 2 months after the decedent’s death, or CERTIFIED BY A CPA.
Within a like period after qualifying as such executor or
administrator, shall give a written notice thereof to the -Time of filing:
Commissioner.
Within 6 months from decedent death
ESTATE TAX RETURN (SEC. 90) The commissioner shall have authority to grant a reasonable
extension for filing the return not exceeding 30 days.
-Instances when the Code requires the filing of an estate tax return:
-Place of filing:
In all cases of transfer subject to the tax imposed herein, or
Where, though exempt from tax, the gross value of the estate An authorized agent bank, or
exceeds P200,000, or Revenue district Officer,
Regardless of the gross value of the estate, where the said estate Collection Officer,
consists of registered or registrable property such as real Duly authorized treasurer of the city or municipality in which the
property, motor vehicle, shares of stock or other similar property decedent was domiciled at the time of his death or
fro which a clearance from the BIR is required as a condition if there is no legal residence in the Philippines, with the Office of
precedent for the transfer of ownership thereof in the name of the the Commissioner.
transferee.

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 COMPILED NOTES: SABABAN, MAMALATEO & CHAVEZ
MARIVIC B. DE GRACIA
TAXATION 2

MARIVIC DE GRACIA

PAYMENT OF TAX (SEC. 91) DISCHARGE OF EXECUTOR OR ADMINISTRATOR FROM

GR: pay-as-you-file system
EX: when the Commissioner finds that the payment on the due date of
the estate tax would impose undue hardship upon the estate, he may
extend not to exceed:
PERSONAL LIABILITY (SEC. 92)
-should make a written application to the Commissioner for determination
of the amount of the estate tax and discharge from personal liability
therefor.

Judicial settlement- 5years
Extrajudicial settlement- 2 years
-application to file for extension of time shall be filed with the Revenue
district officer (RDO) where the estate required to secure its TIN and file
the return.
-No extension will be granted by the Commissioner in cases of
negligence, intentional disregard of rules and regulations, or fraud on the
part of the taxpayer.
-the executor or administrator, upon payment of the estate tax shall be
discharged from personal liability for any deficiency in the tax thereafter
found to be due.
DEFICIENCY (SEC 93)
-the amount by which the estate tax exceeds the amount shown in the
estate tax return, or
-if no amount is shown upon the return or if there is no return, the amount
by which the tax exceeds the amounts previously assessed.

-in case the available cash of the estate is not sufficient to pay its total
estate tax liability, the estate may be allowed to pay the tax by instalment
and a clearance shall be released only with respect to the property
corresponding on which has been paid.
COLLECTION OF ESTATE TAX
PAYMENT BEFORE DELIVERY BY EXECUTOR OR ADMINISTRATOR
-No judge shall authorized the executor or judicial administrator to deliver
a distributive share to any party interested in the estate UNLESS a
certification from the Commissioner that the estate tax has been paid is
shown. (Sec. 94)

-Being a NATIONAL TAX as provided under SEC 21b of the NIRC is
collected by the BIR.
-Being the lifeblood of the government, the collection is not conditioned
upon any outcome of a probate proceeding.
-There is nothing in the Tax code, and in the pertinent remedial laws that
implies the necessity of the probate or estate settlement court’s approval
of the state’s claim for estate taxes,before the same can be enforced and
collected. (Marcos II v. CA)
Distribution of the estate properties can only be made:
1. After all the debts, funeral charges, expenses of administration,
allowance to the widow, and ESTATE TAX have been paid; or
2. Before payment of said obligations only if the distributes or any of
them gives a BOND in a sum fixed by the court conditioned upon
the payment of said obligations within such time as the court
directs, or when provision is made to meet those obligations.
(Estate of Hilario Ruiz)

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 COMPILED NOTES: SABABAN, MAMALATEO & CHAVEZ
MARIVIC B. DE GRACIA
TAXATION 2

MARIVIC DE GRACIA

DUTIES OF CERTAIN OFFICERS AND DEBTORS (SEC. 95)
-The Registry of deeds shall not register the property unless a
certification from the Commissioner that the tax fixed had been paid.
-attorney who executed the extrajudicial partition or the judicial
settlement is obliged to file a petition or pleading with the court
-the notary public who notarized the settlement of the estate
-the city or provincial engineer who made the cadastral survey for
purposes of partition.
-a debtor of the deceased to pay only after a certification of the
Commissioner that the tax has been paid is shown.
-such debtor may be allowed to pay his debt even without such
certification, provided that the amount of the debt is included in the
enventory of the estate of the deceased.
PAYMENT OF TAX ANTECEDENT TO THE TRANSFER OF SHARES,
BONDS, OR RIGHT (SEC. 97)
-For the transfer to the NEW owner to be effected, there must be a
showing of the certification from the Commissioner that the estate tax has
been paid.
-If a bank has knowledge of the death of a person, who maintained a
bank deposit account alone or jointly with another, shall not allow any
withdrawal from the said deposit account, unless the Commissioner has
certified that estate tax had been paid.
-the administrator or any of the heirs of the decedent may, upon
authorization by the commissioner withdraw an amount not exceeding
P20,000 without the said certification.

RESTITUTION OF TAX UPON SATISFACTION OF OUTSTANDING

OBLIGATIONS (SEC. 96)

-If after the payment of the estate tax, NEW obligations of the decedent
shall appear, and the person interested shall have satisfied they by order
of court,
-they shall have a right to the restitution of the proportional
part of the tax paid.

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