In September 2024, Amelia, a Filipino citizen, transferred 10,000 shares of Makati Corp. which is a domestic corporation not listed on any stock exchange, to her nephew Bernard. The transfer was documented as a contract of sale with a stated consideration of ₱1,500,000. At the time of the transfer, the book value per share (which serves as the FMV for unlisted shares under applicable regulations) was ₱400 per share, giving a total FMV of ₱4,000,000. The BIR assessed donor's tax on the difference of ₱2,500,000 between the FMV (₱4,000,000) and the actual consideration (₱1,500,000), treating the shortfall as a deemed gift. Amelia argues that since the transfer was a sale supported by a written contract of sale and actual monetary consideration, it cannot give rise to a taxable gift or donation. Is the BIR's assessment of donor's tax correct? Explain. How much is the donor's tax due, if any?