Two considerations: 1) Since most of the real estate values are capital gains, there might be a net financial advantage when and if real estate was sold after the trusts had been disallowed, inasmuch as capital gains income tax rates are (much) higher than (Massachusetts) estate tax rates. The disallowance of the Trusts would set a much higher basis from which capital gains would be calculateds, and capital gains taxes would be corresondingly much lower. 2) The good faith existence of any real estate trust will be corroborated by the manner in which its assets are sold. When real estate in trust is sold, it would arguably be improper for a deed to be issued until all shareholders had voluntarily sold their shares of beneficial interest either to the Trustee as middleman or preferably to a third party middleman to whom the Trustee would simultaneously convey the legal interest. Then the middleman, holding both the legal interest and all beneficial interests, would be in a position to issue a deed "in fee simple" with or without, but preferably without warranties.