Several recent fiduciary cases have results as unexpected as the ending of an O'Henry short story. A Pennsylvania trustee in a case called Sky Trust1 diversified the assets of a trust out of the trustees' own stock — and was surcharged for its efforts. In SunTrust,2 a Georgia co-trustee that followed the beneficiary's direction to invest wholly in tax-free bonds was exonerated from a surcharge — despite missing a 200 percent appreciation enjoyed by sister
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