A donation on account of marriage was made by Mr$.$ G to Mr$.$ A$,$ when the fair vaue of the property subject of donation was P$2$M$,$ donor's tax was paid. Upon death of Mr$.$ G$,$ the BIR considered he the donation of as mortis causa $($ to take effect upon death$).$ Fair value of property at time of death is P$4$M$.$

What is the legal consequence of the action of the BIR?

A$.$ no estate tax to be paid

B$.$ Estate tax due is $P240,000$

C$.$ Estate tax due is $P135,000.$

D$.$ All of the above