TAXATION - PROPERTY ‑- REAL ESTATE EXCISE TAX ‑- TRANSFER BY DEED IN LIEU OF FORECLOSURE ‑- RESALE UNDER CONTRACT OF SALE 1. The real estate excise tax does not apply to a transfer of real estate by deed from a mortgagee to the mortgagor in lieu of foreclosure. 2. Same:   The tax does apply to the immediate resale of the property by the mortgagee to the mortgagor under a contract of sale. 3. Same:   The fact that the two transfers constitute an over-all agreement between the parties does not affect the tax consequences.