Joe’s will required property to be put in trust with a bank as trustee. His will named his sister Tess to receive the trust income annually for life and empowered Tess to will the property to whomever she so desires. In addition, Tess may require that the trustee make distributions of principal to her for her health or support needs. Tess plans to leave the property by will to two of her three children in equal shares. Tess seeks your advice about whether the trust will be included in her gross estate. Respond to Tess.