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WHERRY, Judge: Respondent determined a Federal income tax
deficiency in the amount of $4,448 with respect to the 2000
taxable year of the William L. Rudkin Testamentary Trust (the
trust). The sole issue for decision is whether investment
advisory fees paid by the trust are fully deductible under the
exception provided in section 67(e)(1) or whether the fees are
deductible only to the extent that they exceed 2 percent of the
trust’s adjusted gross income pursuant to section 67(a).1
FINDINGS OF FACT
The majority of the facts have been stipulated and are so
found. The stipulations of the parties, with accompanying
exhibits, are incorporated herein by this reference.
Michael J. Knight serves as trustee of the trust and provided an
address in Fairfield, Connecticut, at the time the petition in
this case was filed.
The trust was established under the will of Henry A. Rudkin
on April 14, 1967.2 Henry A. Rudkin’s family was involved in the
founding of Pepperidge Farm, a food products company. Pepperidge
Farm was sold to Campbell Soup Company in the 1960s, and the
1 Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the year in issue, and Rule
references are to the Tax Court Rules of Practice and Procedure.
2 The will refers to the trust as the “William L. Rudkin
Family Testamentary Trust”, but all other documents contained in
the record omit “Family” from the name. The difference is not
material.
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Last modified: May 25, 2011