A Court of Appeals in Washington state has affirmed a trial court decision denying claims by the son of donors to a private foundation who sought to obtain, as residual beneficiary under their will, real estate that they had given to the Foundation before their death. Kenneth and Catherine Frank had created a private foundation in 1993 and conveyed all of their interest in a section of land known as Cranberry Lake to it by 1994. The deed included an after acquired property clause in which they said that they also conveyed “all after-acquired title” in the land. In 1995, their son deeded to them his interest in 80 acres of Cranberry Lake and they subsequently deeded that to the Foundation in...