Mellon Bank, N.A. v. United States

OPINION

ANDEWELT, Judge.

I

In these consolidated tax refund actions, plaintiffs, Mellon Bank, N.A., and Real Estate Trust, seek a refund of income taxes paid by 13 trusts created for the benefit of *188members of the Richard K. Mellon family.1 The dispute at issue involves tax years 1989 through 1992 and focuses on the deductibility under I.R.C. § 67 of fees paid by the trustees for two types of trust services: investment strategy advice provided by private investment advisors, and accounting, tax preparation, and management services provided by Richard K. Mellon & Sons (RKM & S). This action is…