Woody wants to transfer some of the income from his investment portfolio to his daughter Wendy, age 12. Woody wants the trust to be able to accumulate income on Wendy’s behalf and to meet any excessive expenses associated with her chronic medical conditions. Furthermore, Woody wants the trust to protect Wendy against his premature death without increasing his Federal gross estate. Thus, Woody provides the trustee with the powers to purchase insurance on his life and to meet any medical expenses that Wendy incurs.

The trust is created in 2019. A whole life insurance policy with five annual premium payments is purchased during that year. The trustee spends $30,000 for Wendy’s medical expenses in 2022 (but in no other year). Woody dies in 2023. Has the trust been tax-effective? Explain.