If a decedent leaves property to two or more persons, the deductions specified in the Inheritance Tax Law will ordinarily be prorated against the market value of the property to which each such person is entitled, according to the ratio between such value and the market value of all property in the decedent's estate. However, if for any reason the property left to a particular transferee is not chargeable with the payment of the items for which deductions are permissible, no portion of the deductions may be allowed against such property.
NOTE: Reference: Section 13982, Revenue and Taxation Code.
Cal. Code Regs. Tit. 18, § 13982