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Supreme Court gives IRS win in trust case

January 16, 2008

The U.S. Supreme Court ruled today that deductions for trusts and estates are subject to the same 2 percent of adjusted gross income limits that individual
taxpayers face.

The case, Knight v. IRS, revolved around a relatively tiny tax amount: $4,448.

Yeah, I do think almost $4,500 is a tidy sum. But I use the word relative because that amount was in connection with a tax return filed by a trust established for the heirs of the Pepperidge Farm company.

Milano_cookies
When you’re talking about Pepperidge Farm (yes, I said "fahhrm" in my head as I typed that), you’re not just talking yummy Milano cookie crumbs.

The trust was set up with money from the sale of Pepperidge Farm to
Campbell Soup and in 2000, the year of
the disputed return, it had $2.9 million in assets and $625,000
in income.

It reported expenditures of $22,241 on investment advice and
deducted the full amount on its tax return.

Uh-uh, said the IRS. Expenses can be deducted only to the extent they exceeded the 2
percent
floor. The difference was the disputed $4,448.

The Supreme Court, in a unanimous decision, said Uncle Sam is right. That’s why you’re seeing a lot of mopey trust managers and beneficiaries today.

At least in this case, we regular taxpayers can take solace in the fact that while the IRS won, it was folks much, much wealthier than us who came out on the losing end of the tax battle.

This Forbes’ story has some good background on the suit, as does this bulletin from Cornell University Law School. This AP story has a bit more on the Court’s decision.

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TAX-SAVVY WAYS 
TO WRAP UP 2026

It’s over! With October’s extended filing deadline behind us, it is now time to focus on year-end moves to reduce your 2026 tax bill. 

You’ll find ways to do just that on the Tax Tips page (see the More Tax Posts drop-down menu at the top of the blog), as well as the separate tax tip pages for each month, notably October through December. If you’re on the Tax Tips page, you’ll find a monthly list at the end of this column. If you’re on another blog page, you can head straight to the October tips; at the bottom of that tips page you’ll find links to all the other 11 months’ collections of tax advice.

Not to spoil what you’ll find in that tax advice, but it does cover such things as tax deductions for charitable donations, investment moves that could reduce tax due, and ways to max out your tax-favored retirement savings. 

Finally, as the year winds down, things get hectic. There are lots of other things to occupy our time, like the much more fun upcoming holidays. But don’t lose sight of taxes, since timing is key. To be of use, most tax moves must be made by the end of the tax year. That’s Thursday, Dec. 31, which also is the last business day of the year. 

So that you don’t miss that final tax year deadline, also keep an eye on the countdown clock below. It will keep you on top of just how much time is left to make important, tax-saving moves. (Note: I’m in the Central Time Zone, so adjust accordingly for where you live.)

Comments
  • Kellsboro Jack

    Interesting story and I won’t worry too much about the Rudkin family starving ;>
    Margaret Rudkin’s (who founded the company with her husband William) heirs married into another who had far deeper pocksts: the Bostwick family. Jabez Bostwick was a key Standard Oil player such that his wife – Helen C. Bostwick – died in 1920 with an estate valued then at $29 million.

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