Estate of Hon Hing Fung, Bernard Fung v. Commissioner

117 T.C. No. 21

UNITED STATES TAX COURT ESTATE OF HON HING FUNG, DECEASED, BERNARD FUNG, EXECUTOR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 2173-00. Filed December 10, 2001. D, a nonresident alien for U.S. tax purposes, possessed at the time of his death interests in certain properties located in the State of California. D’s interests in two of these parcels, one of which was subject to a promissory note secured by a deed of trust, were contained in his residuary estate. D’s will provided for his surviving spouse to receive a three-eighths fractional interest in…