The taxpayer of gift tax shall be the donor of gift. However, the donee shall be liable for payment under any of the following circumstances:
(1)The donor’s whereabouts is unknown;
(2)The donor fails to pay gift tax within the time limit prescribed herein and does not have any property in the ROC for enforcement ; or
(3) The gift tax has not been assessed by the time of death of the donor.
If there are more than one donee in the case described in the foregoing paragraph, the donees shall be liable for payment of gift tax computed according to this Act in proportion to the value of the property received by each donee.