dissenting: I am unable to agree with -the ruling of the majority of the Board. It seems clear that the trust in question brings the instant case within the reasoning of the Court of Appeals for the Eighth Circuit in Willcuts v. Douglas, 73 Fed. (2d) 130, where the court held that such a trust relieved the trustor of the payment of legal obligations he was bound to meet and thus directly benefited him. Any other decision points the way to the evasion of taxes justly due.