Michael J. Knight, Trustee of the William L. Rudkin Testamentary Trust v. Commissioner of Internal Revenue (552 U.S. 181)
U.S. Supreme Court · decided January 16, 2008 · Supreme Court Database (Spaeth)
- Citation
- 552 U.S. 181 · 128 S. Ct. 782
- Decided
- January 16, 2008
- Term
- October Term 2007
- Vote
- 9–0
- Majority author
- Justice Roberts
- Issue area
- Federal Taxation
- Disposition
- Affirmed
- Outcome
- Petitioning party lost
- Ideological direction
- Liberal
Opinion excerpt
Chief Justice Roberts delivered the opinion of the Court. Under the Internal Revenue Code, individuals may subtract from their adjusted gross income certain itemized deductions, but only to the extent the deductions exceed 2% of adjusted gross income. A trust may also claim those deductions, also subject to the 2% floor, except that costs incurred in the administration of the trust, which would not have been incurred if the trust property were not held by a trust, may be deducted without regard to the floor. In the case of individuals, investment advisory fees are subject to the 2% floor; the question presented is whether such fees are also subject to the floor when incurred by a trust. We hold that they generally are and therefore affirm the judgment below, albeit for different reasons than those given by the Court of Appeals. I The Internal Revenue Code imposes a tax on the “taxable income” of both individuals and trusts. 26 U. S. C. § 1(a). The Code instructs that the calculation of taxable income begins with a determination of “gross income,” capaciously defined as “all income from whatever source derived.” § 61(a). “Adjusted gross income” is then calculated by subtracting from gross income certain “above-the-line” deductions, such as trade and business expenses and losses from the sale or exchange of property. § 62(a). Finally, taxable income is calculated by subtracting…
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