In Estate of England (1991) 233 Cal.App.3d 1, the husband and wife held real property in joint tenancy. The husband died, having executed a holographic will 12 days earlier in which he purported to "terminate my joint tenancy interest" in the property and devise it to his son. (Id. at p. 3.) The issue was whether the will was effective to sever the joint tenancy and thereby prevent the wife from taking the property through the right of survivorship. The appellate court concluded that the "will could not be effective to sever the joint tenancy in the property because it was neither notarized nor recorded as required by subdivision (c) [of section 683.2]." (Id. at p. 5.) The wife therefore owned the entire property.