Alfonso DiFilippo and his brother, Pasquale, owned a parcel of real property as tenants in co m mon. Pasquale died in 1961, leaving a life estate in the property to his widow, Annie, with the remainder estate when Annie dies to Alfonso.

Annie died in 1985. Alfonso died in 1969, leaving his interest in the property to his wife, Maria.

What interest did Maria own in the pro p erty when she died in 1981? DiFilippo v. DiFilippo , 640 N.E.2d 1120 (MA).