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Supreme Court Docket[Download November 26, 2007 Argument Calendar PDF]
Knight v. Commissioner of Internal Revenue No. 06-1286 Title: Michael J. Knight, Trustee of the William L. Rudkin Testamentary Trust v. Commissioner of Internal Revenue Subject: Probates, Trusts & Estates, Administrative Expenses, 26 U.S.C. section 67(e), Deductions, Tax Law Question:
There is a deep, irreconcilable and widely noted conflict among the Second, Fourth, Sixth and Federal Circuits about the meaning of 26 U.S.C. section 67(e) — which permits trusts and estates to deduct on their income tax returns certain administrative expenses — and whether the statute permits fees for investment management and advisory services to be fully deducted on trust's and estate's income tax returns. This is an important and recurring question of federal tax law that involves deductions by trusts and estates that total in the billions of dollars annually. Decisions:
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