WM. PRESTON LANE, JR., GOVERNOR. 225

is liable for the payment of an estate tax under the provi-
sions of the United States Revenue Act of 1926, or any amend-
ments thereto, or under any death tax law of the United
States hereafter enacted, upon or with respect to any prop-
erty required to be included in the gross estate of a decedent
under the provisions of any such law, the amount of the tax,
except in a case where a testator otherwise directs in his will,
shall be equitably pro-rated as between the individual estate
of the decedent and the trust estates created, or transfers
made, by the decedent in his life time so included in said
gross estate, and the fiduciary paying the tax shall be en-
titled to recover from the fiduciaries in possession of said
trust estates and from transferees, the proportionate amount
of such tax with which such funds are chargeable under the
provisions of this section.

The provisions of this sub-section shall apply to estates of
persons dying subsequent to June 1, 1937, and on or before
June 1, 1947.

(3) Contributions to the payment of the estate tax shall be
made as follows:

(a) If any part of the gross estate upon which the estate
tax has been paid consists of the value of property, other
than the true estate, over which decedent had a power of
appointment and which is included in the gross estate under
Section 811 (f) of the Internal Revenue Code, or any amend-
ments thereto, the executor shall be entitled to recover from
the person receiving such property by reason of the exercise,
non-exercise, or release of such power of appointment such
portion of the total tax paid as the value of such property
(i. e. the value at which it is included in the gross estate)
bears to the sum of the net estate and the amount of the speci-
fic exemption allowed in computing the net estate. If there
is more than one such person, the executor shall be entitled
to recover from such persons in the same ratio.

(b) If any part of the gross estate upon which the estate
tax has been, paid consists of proceeds of policies of insur-
ance upon the life of the decedent receivable by a beneficiary
other than the executor, the executor shall be entitled to re-
cover from such beneficiary such portion of the total tax
paid as the proceeds of such policies bear to the sum of the
net estate and the amount of the specific exemption allowed
in computing the net estate. If there is more than one such
beneficiary, the executor shall be entitled to recover from
such beneficiaries in the same ratio. The effect of contribu-
tion hereunder by a trustee beneficiary for all purposes of
the trust shall be the same as if the principal of the policy