on november 29 , 1963 the court of tax appeals rendered judgment holding manuel b. pineda liable for the payment corresponding to his share of the following taxes : deficiency income tax 1945 p135.83 1946 436.95 real estate dealer 's fixed tax 4th quarter of 1946 and whole year of 1947 p187.50 the commissioner of internal revenue has appealed to us and has proposed to hold manuel b. pineda liable for the payment of all the taxes found by the tax court to be due from the estate in the total amount of p760.28 instead of only for the amount of taxes corresponding to his share in the estate.1awphl.nt manuel b. pineda opposes the proposition on the ground that as an heir he is liable for unpaid income tax due the estate only up to the extent of and in proportion to any share he received .