The will of the taxpayer's late husband directed that the executors pay to the credit of an income account the annual net revenues from a trust fund, and directed that such money should be under the sole control of the taxpayer to be used by her for the maintenance of her and her children and otherwise for the benefit of her and her children as she in her sole discretion might from time to time determine. In finding that the estimated portion of the income received by the taxpayer which was used for the maintenance of her children was not her income, Kellock J. stated (p. 1096):
... the wife, being obligated to apply the income needed for the benefit not only of herself but also for the children, although her discretion is absolute ... has an interest limited to that which she appropriates for herself, and the children become entitled to the remainder in the proportions she from time to time determines.