A trust provides that all income is payable to W for life, with the remainder to the children. The trustee has the power to invade corpus for the benefit of W. For the current year, the trust received $51,000 of taxable interest; $100,000 of 1231 gains from the sale of land; and $50,000 of 1231 losses from the sale of a building (both allocable to corpus). $1,000 of deductible commissions are chargeable to income. The trustee distributes $55,000