Cory v. Ward

In Cory v. Ward (1980) 106 Cal.App.3d 631, the trustee was authorized to invade the corpus of the trust for the "'support, maintenance, education and/or comfort' of any beneficiary . . . 'up to and including the whole thereof' in the sole discretion of the trustee." (106 Cal.App.3d at p. 640.) The court held that "the provision for invasion of corpus for the purpose, inter alia, of the comfort of the life beneficiary . . . does not constitute an ascertainable standard falling within the exclusion of section 13692, subdivision (a)." (106 Cal.App.3d at p. 642.)