Cory

We granted a hearing in this case to resolve a conflict between Court of Appeal opinions in this and an earlier case. After an *530 independent study of the issue, we have concluded that the careful and scholarly opinion of Judge Lazarus (assigned) for the Court of Appeal, First Appellate District, in this case correctly treats the issues, and we adopt it as our opinion. That opinion, with appropriate deletions and additions, * is as follows:

A brief summaiy of the specific facts upon which this dispute is predicated follows.

Decedent was a resident and national of Japan at the time of his death, September 12, 1972. Starting in 1962, he established and maintained an investment management agency account with the Bank of America in San Francisco. When he died, his portfolio included the following assets, all of which were more specifically listed and described in the inventory and appraisement filed in the probate proceeding:

Respondent concedes at the outset that the “California stocks” referred to in paragraph (a) above were subject to inheritance tax, and that the estate was further hable to pay any “pickup” tax equal to the state tax credit allowed decedent’s estate…