decedent, whichever event first occurs, shall give written notice thereof to the Collector." The precise application of this provision does not seem entirely clear. Obviously it does not and as a practical matter cannot effectively apply to the representatives of non-resident estates which are not required to make return hereunder; and if the provision does not apply to the estates of non-residents which are not required to make return hereunder, the question may be pertinent as to whether a notification is required of the representatives of such resident estates as do not make return. On the other hand, the representative of an estate in many cases cannot know the amount of the gross estate, and thus whether a return is required hereunder, until after the expiration of the time required for the notice to the Collector as above mentioned. In view of the wording of the Statute, therefore, it may be deemed advisable, in respect of resident. estates of whatever amount, for the representatives thereof to file proper notice with the Collector, unless and until the apparent meaning of the Statute is modified by Treasury regulation or otherwise. It seems reasonably certain that the Statute intends the notice to the Collector to be made by the representatives of all estates required to make returns hereunder, whether resident or non-resident. The tax levied hereunder shall be due one year after the decedent's death, and shall be paid to the Collector with whom the return has been filed. Should the tax be unpaid within sixty days after it is due, excepting when there is reasonable cause for further delay, the Collector shall commence proceedings for the sale of the property of the decedent. In cases of payment before the expiration of one year after the decedent's death, a discount of five per cent. per annum shall be allowed on the period of such prior payment; if the tax is not paid within ninety days after the expiration of the year, a penalty of ten per cent. per annurn shall be imposed, calculated from the date of the decedent's death. If the Collector finds the tax cannot be determined on account of claims against the estate, necessary litigation, or other unavoidable delay, the interest or penalty shall be at the rate of six per cent. per annum from the time of the decedent's death until the cause of delay is removed, and thereafter, at the rate of ten per cent. Litigation to defeat the payment of the tax shall not be deemed "necessary litigation" hereunder. Should the representative of an estate fail to pay such tax as may be hereby imposed upon any gifts or trusts created in contemplation of death, it seems that the transferee or trustee of such property shall be personally liable for the tax on that part of the property which The Tax When Due Liability of Adjustment of Tax Penalties Lien Exemptions belonged to the decedent at the time of the transfer or the creation of the trust. In case the exact amount of tax cannot be determined for any reason, provision is made for the deposit of funds pending final settlement, the amount to be sufficient in the opinion of the Collector of Internal Revenue. When the tax is finally determined any excess de posited with the Collector shall be refunded by the Commissioner of Internal Revenue, and any additional amount due thereon shall be then paid; for non-payment of any additional amount due, a penalty of ten per cent. is imposed thereon, calculated from the date of notification. Provision is also made by the Statute for the reimbursement of any person who has paid a tax in order to protect interests involved. The penalty for false statement hereunder shall not exceed $5,000, or imprisonment not to exceed one year, or both. Failure to comply with any duty imposed by the Statute shall subject the person liable therefor to a penalty of not exceeding $500 and costs of action. It is provided by the Statute that the lien of unpaid taxes hereunder shall rest upon the gross estate of the decedent for a period of ten years, except as to that part used for the payment of charges against the estate and the expenses of administration allowed by the court having jurisdiction. In some cases property of the estate sold to a bona fide purchaser for value appears to be divested of this lien, but it seems advisable in these comments merely to draw attention to this possibility and to suggest that necessary rulings and possibly decisions by the courts may so interpret the Statute as to make its practical application unmistakable. A lien against the property of an estate for a period of ten years, and exemptions from such a lien, are obviously matters of considerable importance. One of the fundamental features of the Law is the levying of the tax on the estate in its entirety; and it is interesting to note in that connection that the Statute expressly declares its intention to have the tax paid out of the estate itself before its distribution, rather than out of the distributive shares thereof, in so far as is practicable and unless otherwise directed by will. Subject to contrary ruling or decision, it therefore seems a fair inference, that in so far as the assets of the estate will permit, and unless otherwise directed by the testator, the separate bequests of a will shall not be charged with or decreased by the Federal Estate Tax. Tax Paid Income Tax Law Persons Rates of PART I. On Individuals. Sec. 1. (a) That there shall be levied, assessed, collected, and paid annually upon the entire net income received in the preceding calendar year from all sources by every individual, a citizen or resident of the United States, a tax of two per centum upon such income; and a like tax shall be levied, assessed, collected, and paid annually upon the entire net income received in the preceding calendar year from all sources within the United States by every individual, a nonresident alien, including interest on bonds, notes, or other interestbearing obligations of residents, corporate or otherwise. (b) In addition to the income tax imposed by sub-division (a) of this section (herein referred to as the normal tax) there shall be levied, assessed, collected, and paid upon the total net income of every individual, or, in the case of a nonresident alien, the total net income received from all sources within the United States, an additional income tax (herein referred to as the additional tax) of one per centum per annum upon the amount by which such total net income exceeds $20,000 and does not exceed $40,000, two per centum per annum upon the amount by which such total net income exceeds $40,000, and does not exceed $60,000, three per centum per annum upon the amount by which such total net income exceeds $60,000 and does not exceed $80,000, four per centum per annum upon the amount by which such total net income exceeds $80,000 and does not exceed $100,000, five per centum per annum upon the amount by which such total net income exceeds $100,000 and does not exceed $150,000, six per |