Andre Maximov, as Trustee for the Benefit of H. Robbin Fedden U/a Dated 10/24/47 v. United States

CLARK, Circuit Judge.

The taxpayer, Andre Maximov, is the successor trustee of an inter vivos trust created in 1947, under the laws of Connecticut, by H. Robbin Fedden. Under the terms of the trust instrument all income is to be paid to the grantor during his life; on his death the income is payable to his wife if she survives him and is still married to him. On her death if she qualifies for this life estate, or on the grantor’s if she does not, the entire principal of the trust is to be paid to the surviving issue of the grantor in equal shares, per stirpes, with limitations not here…