Estate of Leon Amiel, Deceased, Leon L. Amiel, Administrator, c.t.a. - Page 12

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          invasion for the current income beneficiary only.  That is,                 
          according to petitioner, during Hilda's lifetime the trustees could         
          invade the corpus of the Part B trust only for Hilda's benefit.  We         
          disagree.  In our opinion, the trustees' invasion power is not as           
          limited as petitioner asserts.  We believe decedent wanted to               
          permit the trustees to invade the trust corpus "at any time",               
          including the lifetime of Hilda, should it be necessary to benefit          
          Hilda, Katherine, Joanne, or Katherine's and Joanne's children.  In         
          this regard, article four, paragraph C, permits such invasion for           
          the support, maintenance, health, education, comfort, or general            
          welfare of "my [decedent's] wife or any such beneficiary".                  
               Article five of decedent's will directs that the trustees              
          provide decedent's descendants with adequate funds to attend                
          suitable schools, colleges, and professional schools.  This                 
          provision demonstrates that decedent's desire under article four,           
          paragraph C, to permit invasion of corpus for educational purposes          
          was primarily for the benefit of decedent's grandchildren, who              
          could be attending school during the lifetime of Hilda.  Article            
          five also provides that the trustees are not to be limited "in any          
          way" in providing decedent's wife, daughters, and grandchildren             
          with adequate funds to maintain the standard of living they enjoyed         
          "at the time of my death".                                                  
               Article five permits the trustees to invade corpus to provide          
          for "special family situations which may arise from time to time".          
          These are defined to include furnishing a home at the time of               




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