In Ollick v. Rice, 16 Ohio App. 3d 448, 16 Ohio B. 529, 476 N.E. 2d 1062 (Ohio App. 1984), the beneficiary of an inter vivos trust filed an objection in an estate to the payment of certain fees and to the accounting. The beneficiary's standing was challenged. Id. at 1070-1072.
The will provided that, except for three specific bequests, all of the estate's assets were to be distributed to the inter vivos trust. Id.
The court recognized cases holding that beneficiaries under a testamentary trust have standing to except to an account filed in an estate and concluded that, "under the factual situation presented here, the beneficiary's interest is almost identical to that of a beneficiary taking under a testamentary trust." Id.