Kautzmann v. United States

OPINION AND ORDER

BATTIN, Chief Judge.

Presently pending before the Court are plaintiffs’ and defendant’s cross-motions for summary judgment. For the reasons stated below, plaintiffs’ motion is denied and defendant’s motion is granted.

FACTS AND CONTENTIONS

At issue is the deductibility of a $7,500.00 fee paid-by the plaintiffs in 1976 to establish a family trust prepared by Estate Guardian Educational Trust (E.G.E. T.). Plaintiffs terminated the trust in the fall of 1977 upon the advice of their attorney that the trust would not achieve the tax results anticipated. Plaintiffs have been…