In any case where a decedent appoints or names one or more executors or trustees and makes a devise of property to such fiduciaries in the decedent's will in lieu of commissions or allowances or appoints him, her, or them a residuary legatee or legatees, the transfer to such fiduciary or fiduciaries of that portion of the property in excess of the reasonable compensation fixed by the Superior Court having jurisdiction in the matter, is subject to the New Jersey transfer inheritance tax.
N.J. Admin. Code § 18:26-5.5