William L. Rudkin Testamentary Trust v. Comm'r
United States Tax Court
T is a trust established in 1967. The trustee engaged an outsidefirm to provide investment management advice for T, and the firmwas paid $ 22,241.31 for such services during the 2000 taxableyear. On its Federal income tax return, T deducted these fees(rounded) in full.
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T is a trust established in 1967. The trustee engaged an outsidefirm to provide investment management advice for T, and the firmwas paid $ 22,241.31 for such services during the 2000 taxableyear. On its Federal income tax return, T deducted these fees(rounded) in full. Held: The investment advisory fees paid by T are notfully deductible under the exception provided in sec. 67(e)(1),I.R.C., and are deductible only to the extent that they exceed 2percent of the T's adjusted gross income pursuant to sec. 67(a),I.R.C.
1Opinion of the Court
WILLIAM L. RUDKIN TESTAMENTARY TRUST U/W/O HENRY A. RUDKIN, MICHAEL J. KNIGHT, TRUSTEE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
William L. Rudkin Testamentary Trust v. Comm'r
No. 3297-04
United States Tax Court
124 T.C. 304; 2005 U.S. Tax Ct. LEXIS 20; 124 T.C. No. 19;
June 27, 2005, Filed
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…
2Cases cited8 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- E. Norman Peterson Marital Trust, Chemical Bank, Trustee v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1996
- Peterson Marital Trust v. CommissionerUnited States Tax Court · 1994
- Scott v. United StatesCourt of Appeals for the Fourth Circuit · 2003
- Mellon Bank, N.A. v. United StatesCourt of Appeals for the Federal Circuit · 2001
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