Garth establishes a trust, which will pay all income to Garth's child, Carrie, for life. At Carrie's death, the trust will terminate and any remaining property will be distributed to Carrie's children. Garth names his sister, Loretta, as the trustee. In year 3, Loretta makes a loan to Garth from the trust assets, for which he provides full security. The promissory note provides for market-rate interest. The balance due on the loan at the end of the trust's tax year is $50,000. Is Garth treated as the owner of any portion of the trust assets in year 3