In Re The Matter Of: The Czarnecki 2011 Revocable Living Trust

Court of Appeals of Washington·Decided August 17, 2026·No. 87901-4·Unpublished

Opinion

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

IN THE MATTER OF THE CZARNECKI 2011 REVOCABLE No. 879014-I LIVING TRUST, dated October 24, 2011. DIVISION ONE

NICHOLAS CZARNECKI, an UNPUBLISHED OPINION individual,

Appellant,

v.

RONALD CZARNECKI, an individual and as the trustee of the Czarnecki 2011 Revocable Living Trust,

Respondent.

HAZELRIGG, C.J. — Nicholas Czarnecki petitioned the trial court under the Trust and Estate Dispute Resolution Act 1 for an accounting of a family trust and removal of the trustee based on allegations that his father, Ronald Czarnecki, the sole trustee and one of the original trustors, had wrongfully disbursed trust income to himself and had been doing so for some time. After a bench trial, the petition was denied in full. On appeal, Nicholas contends that the trial court erred in virtually every aspect of its decision, as well as entry of judgment. We disagree and affirm.

1 Ch. 11.96A RCW.

FACTS 2

Ronald (Ron) and Priscilla (Tilly) Czarnecki were married for many years and had three sons, Nicholas (Nick), Erik, and Alan. 3 The couple received separate inheritances over the course of the marriage and used these assets for “joint investments, expenses, and maintenance.” “Tilly inherited interests in three California investment properties (‘California Properties’)” that produced rental income the couple managed together.

Tilly experienced a “health scare” in 2011, and in response, the couple “executed the Czarnecki 2011 Revocable Living Trust, an estate planning document that required the California Properties to be contributed to a bypass trust upon the death of the first spouse (‘Bypass Trust’).” The trust “appointed Erik, Alan, and Nick as [s]pecial [t]rustees of the California Properties with specific powers.” Some of the specific powers were approval of certain transactions, including “[d]istribution or any other transfer” of the real property from the trust, “any lease agreement affecting such property,” the “refinance of any encumbrance on such property or the addition of any new encumbrance” that was not in place when the property was transferred into the trust, or the burdening of the trust property with “a security interest of any kind . . . or otherwise offering any such property as collateral of any kind.” The sons had no other powers over the trust or

2 Unless otherwise noted, the following facts are drawn from the undisputed findings of fact

entered by the trial court following the bench trial, including those that are now verities due to abandonment of challenges to them on appeal. See In re Est. of Jones, 152 Wn.2d 1, 8, 93 P.3d 147 (2004).

3 Because the parties and others involved share the same last name, we use their first

names for clarity. Further, the parties use shortened forms of their first names in briefing, both in referencing themselves and each other, as they did in the trial court. Accordingly, we adopt that convention. No disrespect is intended.

its assets outside of those regarding transfer, alienation, or encumbrance of the California Properties.

In 2016, the couple began building a house in Mexico with the intent to reside there half the year. In 2019, Tilly was diagnosed with lung cancer. The trial court eventually found that, by that time,

Ron’s and Tilly’s accustomed standard of living included having more than $300,000 in savings, owning their home in Everett with a single mortgage, owning their home in Mexico outright, being able to take vacations, and having enough left over income to give gifts to their sons and grandchildren.

The couple faced “considerable medical costs” as a result of Tilly’s diagnosis and opted “to take out additional mortgages on their Everett home” and spend from their savings and Ron’s 401(k) retirement savings account in order to pay for Tilly’s treatment. “At no time did Nick, Erik[,] or Alan offer to financially assist in the payment of Tilly’s treatment.” Ron served as Tilly’s primary caretaker, with minimal assistance, until she passed away at home in October 2021. The trial court later found as follows:

After Tilly passed, Ron struggled emotionally with the idea of staying in the family home where his wife spent her last years and days.

Consequently, he decided to sell the Everett home and move to and live in the Mexico house full time. His decision was based on multiple factors including the fact that living in the Mexico house would generally be more affordable than staying in the Everett home.

By its terms, the revocable trust became irrevocable upon the death of one of the trustors. The revocation provision set out in the revocable trust states that,

While both of the Trustors are living, they shall have the right acting jointly, and either Trustor shall have the right acting on behalf of the marital community,

(a) to revoke this instrument in its entirety,

(b) to partially revoke or modify this instrument,

(c) to withdraw from the operation of the trust any part of the property of the trust estate, and

(d) to transfer to Trustee additional property acceptable to Trustee for administration as a part of the trust estate.

In December 2021, Ron undertook several actions related to the California Properties and the bypass trust that was created under the plain language of the now-irrevocable trust. He “transferred the California Properties to the Bypass Trust by quit claim deeds.” As a result, the trust was now an irrevocable trust that held income-generating property and, therefore, required both a separate employer identification number (EIN) and separate tax returns under federal law. 4 Ron was unaware of these legal implications; he “continued to receive the income from the California Properties into the bank accounts he and Tilly had historically used” and to report the income as part of his personal income on his federal tax return. Ron also did not inform the property managers that he had transferred the title ownership of the properties to the trust.

In January 2022, Ron arrived at the Mexico home. Around this time, he began to use an application on his phone in order “to meet his obligation to prepare the first annual accounting for the Bypass Trust, which would be due at the end of February[] 2023.” Ron also began the necessary work so that the home could serve as a fulltime residence, but his funds were limited due to the previous expenditures related to Tilly’s medical needs. The trial court later found that

4 See 26 U.S.C. § 511 (imposing tax on trusts that produce income); 26 C.F.R. § 301.6011-

10 (filing requirements for trusts); 26 C.F.R. § 1.6012-3(5) (fiduciaries’ obligation to file on behalf of income producing trust); 26 C.F.R. § 301.7701-12 (EIN requirements).

[o]ver the first seven months of 2022, Erik, Alan, and Nick demanded that Ron provide them with information about the Bypass Trust and expressed concern that they were not receiving any benefit from the Bypass Trust.

In August, Ron sent his sons “a rough breakdown of his financial affairs” via e-mail, expressed hope that he would be able to make distributions from the trust to the other beneficiaries in the future, and explained his plan to do so. Ron ultimately spent “approximately $100,000 to complete and make the Mexico [h]ome livable, half of which he paid for using his diminished savings and half which he borrowed from two banks.” This left him in a “significantly worse” financial position than he had anticipated, especially as compared to his assessment “when he made the financial disclosure to his sons in August, as the loans essentially canceled out his social security income leaving only the Bypass Trust as income, and his savings were significantly depleted.”

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In Re The Matter Of: The Czarnecki 2011 Revocable Living Trust, (Wash. Ct. App. 2026).

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