II. Jose Cerna, Filipino citizen, married to Maria Cerna, died in a vehicular accident in NLEX on July 10, 2007. The spouses owned, among others, a 100-hectare agricultural land in Sta. Rosa, Laguna with current fair market value of P20 million, which was subject to matter of a Joint Venture Agreement about to be implemented with Star Land Corporation ( SLC ), a well-known real estate development company. He bought the said real property for P2 million fifty years ago. On January 5,2008, the administrator of the estate and SLC jointly announced their big plans to start conversion and development of the agricultural lands in Sta. Rosa, Laguna, into first-class residential and commercial centers. As a result, the prices of real properties in the locality have doubled. The administrator of the Estate of Jose Cernan filed the estate tax return on January 9, 2008, by including in the gross estate the real property at P2 million. After 9 months, the BIR issued deficiency estate tax assessment, by valuing the real property at P40 million. A ) Is the BIR correct in valuing the real property at P40 million? Explain. ( 3% ) B ) If you disagree, what is the correct value to used for estate tax purposes? Explain. ( 3% )