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