Legal Opinion

William L. Rudkin Testamentary Trust U/W/O Henry A. Rudkin, Michael J. Knight, Trustee v. Commissioner

United States Tax Court

Decided June 27, 2005No. 3297-04Unknown

1Opinion of the Court

124 T.C. No. 19

UNITED STATES TAX COURT WILLIAM L. RUDKIN TESTAMENTARY TRUST U/W/O HENRY A. RUDKIN, MICHAEL J. KNIGHT, TRUSTEE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 3297-04. Filed June 27, 2005. T is a trust established in 1967. The trustee engaged an outside firm to provide investment management advice for T, and the firm was paid $22,241.31 for such services during the 2000 taxable year. On its Federal income tax return, T deducted these fees (rounded) in full. Held: The investment advisory fees paid by T are not fully deductible under the exception provided…

2Cases cited7 opinions

  1. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  2. E. Norman Peterson Marital Trust, Chemical Bank, Trustee v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1996
  3. Peterson Marital Trust v. CommissionerUnited States Tax Court · 1994
  4. Scott v. United StatesCourt of Appeals for the Fourth Circuit · 2003
  5. Mellon Bank, N.A. v. United StatesCourt of Appeals for the Federal Circuit · 2001

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