Not really. I mean, what, exactly, is the worst case scenario?
An audit involving the 1041 (and those are extremely rare) disputing whether she should be filing as a non-grantor?
Doubtful, but you're going to report all of the income, anyway, so they would be left to dispute only the deductibility of the expenses, which it appears you have already litigated (i.e., it is a issue that has already been settled).
