WM. PRESTON LANE, JR., GOVERNOR. 227

in the true estate, whether upon testacy or intestacy or
upon renunciation in case of testacy, the amount of the estate
tax paid by the executor and not reimbursed by contribu-
tions under this section shall be deducted with the adminis-
tration expenses of the decedent as a general obligation of
the true estate, except to the extent the will of the decedent
expressly otherwise directs; provided, however, a spouse who
renounces the will shall not benefit by any exoneration there-
in or herein in his or her favor.

(5) Exoneration by will of the decedent.

(a) A decedent may by his will exonerate any person or
persons otherwise liable for contribution from all or part of
any such contribution; but nothing herein shall be construed to
preclude a decedent from providing by any appropriate means
for the payment of the estate tax without recourse to persons
otherwise liable therefor.

(b) Whenever any decedent shall in substance provide in his
will that any and all estate taxes on his estate shall be paid
out of his estate, such provision shall be construed to exoner-
ate from contribution to the payment of the estate tax all
persons otherwise liable for contribution thereto under the
provisions of this section, unless the decedent shall specific-
ally direct such contribution.

(6) If any person liable to contribution hereunder transfers
any property included in the gross estate of the decedent
upon which estate tax has been paid or is payable by the
executor, to another person, other than a bona fide purchaser
for value, then such transferee shall be jointly and severally
liable with the transferor for the amount of estate tax con-
tribution due under this section by the transferor; provided,
however, that such transferee shall not be held liable for a
sum greater than the excess of the value of the property
(i. e. the value at which it is included in the gross estate)
of which he is such transferee over the value of the considera-
tion paid by him for such property.

(7) No proceeding for the enforcement by the executor of
any contribution to the payment of estate tax under the pro-
visions of this section shall be begun later than one year
after the expiration of the period of limitation upon assess-
ment of the estate tax as provided by Sections 874 and 875
of the United States Internal Revenue Code or any amend-
ments thereto.

(8) The courts of equity of this State shall have exclusive
jurisdiction of all actions under this section to enforce contri-
bution or apportionment with respect to estate taxes.