BIR Ruling No. 169-61

April 12, 1961 BIR RULING NO. 169-61 Mr. J. G. Cam P. O. Box 79 Davao City S i r : Reference is made to your letter dated September 26, 1960, stating as follows: prll "If a man should leave an estate after his death in the form of corporation stocks (taking for granted the corporation has held vast real properties), the questions are: should the estate be taxed on the par value of the stocks, or should it be computed on the basis of the fair market value of the properties?" In reply thereto, I have the honor to inform you that, for estate and inheritance tax purposes, the properties left by a deceased shall be appraised at the fair market value of the stocks as of the time of death, or as of six months thereafter, at the election of the executor or administrator in the case of estate tax or the heirs in the case of the inheritance tax as provided for in Section 91 of the Tax Code, and not on the fair market value of the real properties owned by the corporation. llcd Very truly yours, (SGD.) MELECIO R. DOMINGO Commissioner of Internal Revenue