id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
ftr-409	Champine, Pamela	Taxing Middle Class Trust(s)	2022	59	.pdf	application/pdf	24848	1214	52	They struggled to achieve an equitable result, yet unintentionally failed to do so in every case even as the Circuits split on the meaning of section 67(e).11 The purpose of this article is to explain how courts came to such an inequitable interpretation of section 67(e) even as they tried to avoid that result; to present an interpretation of section 67(e) based on the principle that underlies the Code’s scheme for taxing trust income; and to illustrate how this interpretation produces optimal equity among trust beneficiaries as well as between trust beneficiaries and outright owners. The Code’s scheme for taxing trust income, set forth in Subchapter J of the Code, recognizes that the12 existence of a trust does not necessarily signify wealth or high income.	cache/ftr-409.pdf	txt/ftr-409.txt