In cases where there are two or more heirs to an estate and some heirs have paid their share of estate tax as well as fine, delay penalty and interest, if any, such heirs may apply to the tax authority for issuing a consent to transfer certificate for the purpose of registering co-ownership by inheritance for a real property. Said real property registered as co-ownership may not be split, disposed, hypothecated or have rights transferred before all tax payable on the property is paid off.