BIR Ruling

December 23, 1996 Estate of Rosemarie T. de Toda c/o Ms. Rosemarie T. Delgado (Administratrix of the Estate of Rosemarie T. de Toda) 1745 Adriatico Street Malate, Manila M a d a m : Further to our letter dated December 9, 1996 granting your request for reconsideration of the decision of this Office dated June 7, 1996 in connection with your protest against the deficiency estate tax assessment issued on the estate of Rosemarie T. de Toda involving the amount of P147,931,995.20 covered by Assessment Notice No. FAS-E-91-91-002313 dated July 18, 1991, later revised/modified by this Office in the amount of P98,482,490.20, inclusive of surcharge and interest, please be informed that this Office is willing to lift the warrant of levy on either of the two (2) lots under TCT Nos. 175244 and 175245, situated at Banaba Road, Forbes Park, Makati City, provided that payment and delivery of the amount of P41 M representing the tax lien on the said two properties shall first be made and/or effected. It is further informed that the tax lien annotated on all the remaining properties of the estate shall be lifted and cancelled only upon full payment of the revised deficiency estate tax of P98,682,490.20, plus interest that may have accrued thereon until actual date of payment. LLjur Very truly yours, (SGD.) LIWAYWAY VINZONS-CHATO Commissioner of Internal Revenue