1087. Apportionment of tax due on death.

Where the interest taken by a particular beneficiary is not a sum charged on the property, but the beneficiary is accountable for inheritance tax1 on some part of the property, he is required under the equitable doctrine of contribution to bear a rateable part of the tax which has been paid on the property as a whole2.

Even where the foregoing rule does not apply, the charge to tax is in its nature one which must be borne rateably, according to the beneficial interests of the parties in the property charged