William J. O'neill, Jr. Irrevocable Trust, Sheldon M. Sager, Co-Trustee v. Commissioner of Internal Revenue

SILER, Circuit Judge.

Petitioners, the William J. O’Neill, Jr. Irrevocable Trust (“Trust”) and Sheldon M. Sager, Co-Trustee, appeal the Tax Court’s decision finding a deficiency in the O’Neill Trust’s income tax for the 1987 taxable year. The Internal Revenue Service (“IRS”) issued a Notice of Deficiency for $3,534.00 in tax owed by the Trust. Upon the filing of a petition for redetermination, the Tax Court held that the investment advisory fees paid by the Trust were expenses deductible from adjusted gross income under Internal Revenue Code (“IRC”) § 67(a) only to the extent that they…