The Supreme Court yesterday granted certiorari in Knight v. Commissioner, No. 06-1286 (6/25/07). The Tax Court (124 T.C. No. 19 (2005)) and Second Circuit (467 F.3d 149 (2d Cir. 2006)) both agreed with the Service’s position that a trustee’s payment of fees to an investment adviser are subject to the 2% floor of § 67.
