President & Directors of the Manhattan Co. v. Janowitz
Julius Janowitz created an inter vivos trust in 1933, subsequently modified four times. Following his death in 1937, the trustee initiated an action for judicial settlement of accounts, while his widow, Emma S. Janowitz, challenged the will and trust validity based on her rights under the Decedent Estate Law. The court addressed whether later trust amendments could be incorporated by reference into the will and if the trust was illusory. It affirmed the validity of the will's third paragraph, incorporating the initial trust and the first three amendments but excluding the fourth. Although the trust was found to be illusory against the widow's rights due to donor control, the court ultimately upheld the trust's overall validity, nullifying only the third amendment's $5,000 annual income limitation for the widow to safeguard her interests. An interlocutory decree was issued.