Forte Investment Fund v. State Tax Commission

The Forte Investment Fund (taxpayer), a Massachusetts trust with transferable shares, appeals from a decision of the Appellate Tax Board (board) which disallowed certain deductions claimed in the taxpayer’s 1971 income tax return. The taxpayer was engaged in investing in stocks, bonds, and real estate for the benefit of its shareholders. The board found that the taxpayer was not “a. broker or trader for the public.” In its operations during 1971, it incurred expenses for officers’ salaries, auditing and legal services, custodian and investment advisor fees and general expenses, and foreign…