Legal Opinion

Estate of Fung v. Comm'r

United States Tax Court

Decided December 10, 2001No. 2173-00Published

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 his residuary estate, with the remaining five-eighths going to his sons.

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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 his residuary estate, with the remaining five-eighths going to his sons. In accordance with an agreement executed by the residuary beneficiaries, the two California properties were distributed to D's…

1Opinion of the Court

ESTATE OF HON HING FUNG, DECEASED, BERNARD FUNG, EXECUTOR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Estate of Fung v. Comm'r

No. 2173-00

United States Tax Court

117 T.C. 247; 2001 U.S. Tax Ct. LEXIS 52; 117 T.C. No. 21; 82 T.C.M. (CCH) 4244;

December 10, 2001, Filed

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…

2Cases cited11 opinions

  1. Roseleaf Corp. v. ChierighinoCalifornia Supreme Court · 1963
  2. Cornelison v. KornbluthCalifornia Supreme Court · 1975
  3. Ahmanson Foundation v. United StatesCourt of Appeals for the Ninth Circuit · 1981
  4. Estate of Hubert v. CommissionerUnited States Tax Court · 1993
  5. Commissioner v. Estate of HubertSupreme Court of the United States · 1997

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