Estate of Hon Hing Fung, Deceased, Bernard Fung, Executor - Page 3




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          parties, with accompanying exhibits, are incorporated herein by             
          this reference.  Decedent was a citizen of Hong Kong, legally               
          resident in Kowloon, Hong Kong, when he died testate in the                 
          Commonwealth of Massachusetts on September 5, 1995.  At all                 
          relevant times, decedent was a nonresident alien for U.S. tax               
          purposes.  Decedent was survived by his wife, Fung Wong Tuen Wang           
          (also known as Norah Fung), likewise a nonresident alien for U.S.           
          tax purposes, and by his five sons.  The executor of decedent’s             
          estate, Bernard Fung, maintained his principal residence in the             
          State of California at the time the petition in this case was               
          filed.                                                                      
               At decedent’s date of death, he possessed ownership                    
          interests in three parcels of real property located in the United           
          States.  Pursuant to community property principles, decedent and            
          his wife each owned a one-half interest in:  (1) 287 Monte Vista            
          Avenue in Oakland, California, consisting of real property                  
          improved with a 3-story, 20-unit residential building; and (2)              
          16597 Calle Victoria in Pacific Palisades, California, consisting           
          of unimproved land.  A third parcel, located at 68 Vernon Street            
          in Oakland, California, and consisting of real property improved            
          with a 3-story, 10-unit residential building, was held by                   
          decedent and his wife as joint tenants.                                     
               In connection with the Monte Vista property, a promissory              
          note dated October 24, 1988, was executed by decedent and his               






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