Value of gross estate for tax purposes

The value of the gross estate of the decedent shall be determined by including the value at the time of death of all property, real or personal, tangible or intangible, wherever situated. If the fair market value of the real property at the time of death of the decedent is P400 million, this market value should be the one used for purposes of determining the gross estate. Whatever is the value of the property after his death (whether it goes up or down) is of no moment for estate tax purposes.