Applicability of the 10-year Prescriptive Period to Collect Inheritance Tax on the Properties of Deceased Pedro M. Laddaran

February 10, 1958 BIR RULING NO. 076-58 The Regional Director BIR Regional District No. 1 Baguio City S i r : This refers to the case of Mrs. Carlota P. Vda. de Laddaran representing estate and inheritance tax on the transfer of certain properties of her deceased husband, Pedro M. Laddaran. According to the memorandum of that Office the return was filed by Examiner Felix Q. Navarro for the estate of the deceased. This is, therefore, a case where the taxpayer failed to file the required return, hence the ten-year prescriptive period in Section 332 of the National Internal Revenue Code is applicable. The assessment having been made within the ten-year period, the Government has still five years from February 14, 1955 within which to collect the tax. In view thereof, you are hereby instructed to take immediate steps to effect collection of the aforesaid tax. LLpr Very truly yours, (SGD.) JOSE ARAAS Commissioner of Internal Revenue