The liabilities transferred together with the gift and deducted as specified under Article 21 of the Act shall be limited to properties with a value and such liabilities has been executed or where such execution can be guaranteed. Where said tax burden involves payment to persons other than the decedent that can be deemed as an indirect gift, no tax deduction claim can be filed.
The amount of tax deduction as set forth in the preceding paragraph shall not exceed the value of the share of taxable properties received.