BIR Ruling [DA-001-97]

January 2, 1997 BIR RULING [DA-001-97] Ms. Virginia S. Sabellano No. 20 Mactan Street Magallanes Village Makati City M a d a m : This refers to your letter dated November 19, 1996 stating that when you filed the estate tax return of your late husband, Col. Geronimo S. Sabellano on February 18, 1994, exactly six months after his death, you failed to include four (4) parcels of land located in Cebu City covered by Transfer Certificates of Title Nos. 63292, 64639, 114921 and 23410 which were entrusted by your husband to his relatives in his hometown in Cebu; and that in order to correct the omission, you intend to file an amended estate tax return by including the aforementioned properties. Based on the foregoing, you now request for the waiver of surcharge, interest and penalties on the deficiency estate tax that may be assessed against you resulting from the late filing of the amended return. In reply please be informed that pursuant to Section 204(i)(b) of the Tax Code, as amended, and in view of the above stated justifiable reasons, except for the interest, the waiver of surcharge and penalties is hereby granted subject to field verification of the mathematical computation of your deficiency estate tax under the amended return. You are therefore advised to file your amended estate tax return at the Revenue District Office No. 48. cdta Very truly yours, BEETHOVEN L. RUALO Deputy Commissioner