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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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