198.32  Prima facie liability for tax.--The estate of each decedent whose property is subject to the laws of the state shall be deemed prima facie liable for estate taxes under this chapter and shall be subject to a lien therefor in such amount as may be later determined to be due and payable on the estate as provided in this chapter. This presumption of liability shall begin on the date of the death of the decedent and shall continue until the full settlement of all taxes which may be found to be due under this chapter, the settlement to be shown by receipts for all taxes due to be issued by the department as provided for in this chapter. Whenever it is made to appear to the department that an estate is not subject to any tax under this chapter, the department shall issue to the personal representative, administrator, or curator, or to the heirs, devisees, or legatees of the decedent, a certificate in writing to that effect, showing such nonliability to tax, which certificate of nonliability shall have the same force and effect as a receipt showing payment. The certificate of nonliability shall be subject to record and admissible in evidence in like manner as receipts showing payment of taxes. A fee of $5 shall be paid to the department for each certificate so issued.