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$649,948.1 Thus, in accordance with community property
principles, decedent’s interest in the property had a value of
$442,500 and was encumbered to the extent of $324,974.
The Calle Victoria property was unencumbered at the time of
decedent’s death. The value of decedent’s interest therein,
again pursuant to community property principles, was $435,000.
The Vernon property had a value of $475,000 and was encumbered to
the extent of $277,257.
Decedent provided for the disposition of his property at
death by means of a will executed on September 27, 1988. The
will first appointed three of decedent’s sons as executors and
trustees of his will and directed that “this will shall be
construed according to the Laws of Hong Kong.” Then, after
making a series of specific bequests, the document dealt with
decedent’s residuary estate in the manner set forth below:
7. I give the residual and remainder of my estate
property and effects of whatsoever nature or kind and
wheresoever situate (including any property over which
I may have a general power of appointment or
disposition by will) to my trustees upon trust to sell
1 The parties stipulated that the total unpaid balance was
$649,958 and that the corresponding balance with respect to
decedent’s one-half interest was $324,974. Since one-half of
$649,958 equals $324,979, we conclude that an error was made in
the stipulation. The estate tax return shows the total
encumbrance as $649,946.67, one-half of which is $324,973.34, and
respondent used the amounts $324,973 and $324,974 in making
calculations which involved one-half of the note’s balance. We
therefore accept the stipulated value of $324,974 as representing
one-half of the encumbrance and assume that the parties intended
$649,948 when referring to the full amount of the debt.
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