Barnette v. McNulty

In Barnette v. McNulty, 21 Ariz. App. 127, 516 P.2d 583, 586 (Ariz. App. 1973), the court encountered a similar situation where the settlor was also the trustee. The court stated: "It would be absurd to require the settlor to call himself up on the telephone as trustee and tell himself that he is revoking the trust. It would be equally absurd to have the settlor send himself a letter as trustee to inform himself as trustee that the trust is to be terminated." Id. In Barnette, the court required some intent to terminate the trust and some communication to the beneficiary or a third party manifesting his decision to revoke. Id.