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It is an interesting case. I agree with Robert Stevens that mistake and misprediction are fuzzy categories. Most mispredictions can be characterized as a mistake of some fact bearing on the misprediction. I believe the essence of a mistake is that an actor could have determined the falsity (or at least the potential inaccuracy) of her assumption with little effort at the time of her action but failed to do so. An error about one's health and life expectancy rarely will be a mistake by this criterion.

But this may be beside the point. I am told by a colleague, Mark Ascher (of Ascher & Scott on Trusts), that a US court might reform a trust or bequest on these facts. Restatement Third, Property: Wills and Other Donative Transfers § 12.2 gives courts a fair bit of discretion to modify donative documents to achieve a donor's tax objectives. The standard is preponderance of the evidence rather than the usual clear and convincing evidence. Modification is not limited to mistake a fact, as it nominally is when reformation is sought for non-tax reasons. For example, a change in tax law may warrant modification.

One final point, under US tax law a reformation or modification for mistake by a state court will not bind a federal court for purposes of determining the federal tax consequences of the events. This is a check against collusive revisions. I gather from Ogden that no party opposed the motion before the court.