Under the estate duty regime, duty was not charged on the value of timber, trees, wood or underwood growing on land comprised in an estate at death. Instead, the tax was deferred until such time as the woodlands were sold, and was then levied at the death estate rate on the net proceeds of sale, subject to the proviso that the sum liable to duty could not exceed the value of the timber at the date of the death. Pending sale, duty was therefore held in suspense, and