Settlor made an inter vivos transfer of certain property in trust for a specified period with directions that the trustees should, in accordance with their own discretion, apply the income of the trust fund toward all or any of several specified purposes. These purposes included the "establishment ... of good understanding, sympathy and co-operation between nations," "the preservation of the independence and integrity of newspapers," and "the protection of newspapers ... from being absorbed or controlled by combines." Summons was taken out by the settlor to have the validity of the trusts determined. Held, the trusts were void because they were non-charitable trusts that were not for the benefit of individuals and consequently could not be enforced, and also because they were for indefinite purposes. In re Astor's Settlement Trusts,  Ch. 534.
John W. Hupp S.Ed.,
TRUSTS-CREATION-SIGNIFICANCE OF CREATION OF HONORARY TRUST BY INTER VIVOS TRANSFER,
Mich. L. Rev.
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