11.5 TRUST'S PAYMENT OF INVESTMENT ADVICE FEES, WRITING A MEMORANDUM TO THE CLIENT'S FILE. Facts: Your client, Aaron Truman, is employed as an elementary school history teacher. Aaron's mother, Mrs. Susan Truman, recently died and her last will and testament provided for the creation of the " Susan Truman Trust" (the "Trust". Most of Mrs. Truman's assets were sold and the proceeds (approximately $2 million) were transferred to the Trust, The principal and income of the Trust are payable to Mrs. Truman's six children at set intervals. Mrs. Truman's will named Aaron as the sole trustee of the trust. Aaron wants to invest the assets of the Trust to earn a fair amount of income, but he has very little personal investment experience. As a result, Aaron hired Erin Russert, a well-respected professional investment adviser, to advise Aaron on how to invest the Trust's assets. You will be meeting with Aaron next week and know that he will be asking you whether there are any limitations on the deductibility of the investment advice fees the Trust is paying to Erin.

Required: Is there any authority indicating whether the Trust can deduct the investment advice fees it is paying to Erin? Research this question, considering the relevant Code section(s), regulation(s), cases, and/or rulings, and write a brief memorandum to the client's file that addresses this question.

Hi, I want a to answer this case as a MEMO. 11.5 Thanks!

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