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Knight's Decided. Now What?

The U.S. Supreme Court's unanimous decision in Knight v. Commissioner1 on Jan. 16, 2008, appears to resolve a controversy that has been raging since the early 1990s concerning whether a trust's investment advisory fees (IAFs) are subject to the 2 percent of adjusted gross income floor (the 2 percent floor.) But Knight leaves open a good many questions, not the least of which is how the Internal Revenue
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The U.S. Supreme Court's unanimous decision in Knight v. Commissioner1 on Jan. 16, 2008, appears to resolve a controversy that has been raging since the early 1990s concerning whether a trust's investment advisory fees (IAFs) are subject to the 2 percent of adjusted gross income floor (the 2 percent floor.) But Knight leaves open a good many questions, not the least of which is how the Internal Revenue Service will finalize its proposed regulations under Internal

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