Pepperidge Farm Legacy

On June 25, 2007, the Supreme Court agreed to hear Knight v. Commissioner1 to decide whether trusts and estates can fully deduct the fees they pay for the investment management and advisory services they receive.2 For the last 10 years, a debate has raged over what level of deductibility Internal Revenue Code Section 67(e)(1) permits for trust investment advisory fees (IAFs). Some courts, notably

On June 25, 2007, the Supreme Court agreed to hear Knight v. Commissioner1 to decide whether trusts and estates can fully deduct the fees they pay for the investment management and advisory services they receive.2

For the last 10 years, a debate has raged over what level of deductibility Internal Revenue Code Section 67(e)(1) permits for trust investment advisory fees (IAFs). Some courts, notably the U.S. Court of Appeals for the Sixth Circuit, have found

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