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decedent's death, regardless of any subsequent contingency value of any subsequent increase or
decrease in value.
(c) Certain items are required by law to be deducted from the appraised gross in arriving at the
net value of the estate on which the inheritance tax is to be computed.
A trustee, no doubt, is entitled to receive a fair compensation for his services. But from this it
does not follow that the compensation due him may lawfully be deducted in arriving at the net
value of the estate subject to tax. There is no statute in the Philippines which requires trustees'
commissions to be deducted in determining the net value of the estate subject to inheritance tax.
(d) It is well-settled that inheritance taxation is governed by the statute in force at the time of the
death of the decedent. Revenue laws, generally, which impose taxes collected by the means
ordinarily resorted to for the collection of taxes are not classed as penal laws, although there are
authorities to the contrary. In the absence of clear legislative intent, we cannot give Act No. 3606
a retroactive effect.
(e) P. J. M. Moore became trustee on March 10, 1924. On that date trust estate vested in him. The
mere fact that the estate of the deceased was placed in trust did not remove it from the operation
of our inheritance tax laws or exempt it from the payment of the inheritance tax. The
corresponding inheritance tax should have been paid on or before March 10, 1924, to escape the
penalties of the laws.
That taxes must be collected promptly is a policy deeply entrenched in our tax system. Thus, no
court is allowed to grant injunction to restrain the collection of any internal revenue tax.
It results that the estate which plaintiff represents has been delinquent in the payment of
inheritance tax and, therefore, liable for the payment of interest and surcharge provided by law in
such cases.
The delinquency in payment occurred on March 10, 1924, the date when Moore became trustee.
The interest due should be computed from that date and it is error on the part of the defendant to
compute it one month later.