Priv. Ltr. Rul. 201244014 (May 30, 2012)

(scrivenor error in naming of Trust 2, instead of Trust 1, as the grantee of deed did not result in a completed gift by the grantor; grantor could correct mistake via civil action seeking deed reformation based on mutual mistake; matter involved attempted funding of trusts for spouses that were to qualify as QPRTs; husband intended to transfer his interest in residence to his trust and wife intended to do the same, but wrong trust named; original deed determined not to reflect parties true intent; upon reformation, there would be no completed gift to wrong trust).