1552                              LAWS OF MARYLAND                       [CH. 907

(b)   If the Orphans' Court finds that it is inequitable to apportion
interest and penalties in the manner provided in this Section because
of special circumstances, it may direct apportionment thereon in the
manner it finds equitable.

(c)   The expenses reasonably incurred by any fiduciary and by any
other person interested in the estate in connection with the determina-
tion of the amount and apportionment of the tax shall be apportioned
as provided in subsection (2) and charged and collected as a part of
the tax apportioned. If the Orphans' Court finds that it is in-
equitable to apportion the expenses as provided in subsection (2), it
may direct apportionment thereof equitably.

(d)   If the Orphans' Court finds that the assessment of penalties
and interest assessed in relation to the tax is due to delay caused by
the negligence of the fiduciary, the court may charge the fiduciary
with the amount of the assessed penalties and interest.

(e)   In any suit or judicial proceeding to recover from any person
interested in the estate the amount of the tax apportioned to the
person in accordance with this Section, the determination of the
Orphans' Court in respect thereto is prima facie correct.

(4)   Method of Proration—(a) The fiduciary or other person re-
quired to pay the tax may withhold from any property of the decedent
in his possession, distributable to any person interested in the estate,
the amount of tax attributable to his interest. If the property in the
possession of the fiduciary or other person required to pay the tax and
distributable to any person interested in the estate is insufficient to
satisfy the proportionate amount of the tax determined to be due from
the person, the fiduciary or other person required to pay the tax may
recover the deficiency from the person interested in the estate. If the
property is not in the possession of the fiduciary or other person re-
quired to pay the tax, the fiduciary or other person required to
pay the tax may recover from any person interested in the estate the
amount of the tax apportioned to the person in accordance with this
Section.

(b)   If property held by the fiduciary or other person is distributed
prior to final apportionment of the tax, the fiduciary or other person
may require the distributee to provide a bond or other security for the
apportionment liability in the form and amount prescribed by the
fiduciary, with the approval of the Orphans' Court having jurisdiction
of the administration of the estate.

(c)   If the fiduciary or other person transfers any property included
in the estate to another person, other than a bona fide purchaser for
value, such transferee shall be jointly and severally liable with the
transferor for the amount of tax apportioned to the transferor under
this Section, less the value at the time of such transfer of any con-
sideration furnished by the transferee for such property.

(5)   Allowance for Exemptions, Deductions and Credits—(a) In
making an apportionment, allowances shall be made for any exemp-
tions granted, and for any deductions and credits allowed by the law
imposing the tax.

(b) Any exemption or reduction allowed by reason of the relation-
ship of any person to the decedent or by reason of the purposes of the
gift inures to the benefit of the person bearing that relationship or