BIR Ruling [DA-425-00]

December 12, 2000 BIR RULING [DA-425-00] 91 (B) DA-253-2000 Mr. Ricardo Mendoza c/o Atty. Ambrosio L. Peralejo 6/F 6760 Ayala Avenue Makati City S i r : This refers to your letter dated June 2, 2000 requesting for an extension of two (2) years within which to pay the estate tax due on the transmission of the said estate to the heirs of the late Teresita Sison Mendoza pursuant to Section 91 (B) of the Tax Code of 1997. It is represented that Teresita Sison Mendoza died on January 2, 2000; that she owned a real property in Galvani Street, San Isidro, Makati; that the deceased left no cash to pay for the estate tax due thereon in the amount of P132,316.62; that in order to pay the said amount, the abovementioned real property will be offered for sale; and that you are now in the process of finding prospective buyers of the said real property. In reply, please be informed that in view of the aforementioned valid and justifiable grounds, your request for an extension of two (2) years reckoned from July 2, 2000, the date fixed for the filing and payment thereof, is hereby granted without the corresponding surcharge and penalties, pursuant to Section 91 of the Tax Code of 1997. However, it is understood that the estate of the late Teresita Sison Mendoza shall be liable to the corresponding interest that may have accrued up to the time of the payment of the estate tax. HCTaAS Moreover, the executor, or administrator, or beneficiary, as the case may be, is required to furnish a bond in such amount not exceeding double the amount of the tax and with such sureties the Commissioner deems necessary conditioned upon the payment of the estate tax in accordance with the terms of the extension. Very truly yours, Commissioner of Internal Revenue By: (SGD.) LILIAN B. HEFTI Deputy Commissioner Legal & Inspection Group