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Deducting Attrny Fees for PLR on 1041

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golfeveryday87

Junior Member
What is the name of your state? Michigan

One of my clients is the Co-Trustee and Co-Beneficiary of a trust that was created when their Uncle passed away. Their Uncle had made the trust the beneficiary of his IRA. The 2 beneficiaries wanted to split the IRA FBO each of them and were told by many investment companies that in order to split the IRA they would need to get a PLR. They paid an attorney to prepare the PLR. Am I allowed to deduct this attorney bill on this years form 1041 based on code section 67(e) (deduction allowed if property not held in trust) or any other code section? Or is there something else I could do with the attrny fees or IRS PLR fees?

Thank you
 


LdiJ

LdiJ

Senior Member
golfeveryday87 said:
What is the name of your state? Michigan

One of my clients is the Co-Trustee and Co-Beneficiary of a trust that was created when their Uncle passed away. Their Uncle had made the trust the beneficiary of his IRA. The 2 beneficiaries wanted to split the IRA FBO each of them and were told by many investment companies that in order to split the IRA they would need to get a PLR. They paid an attorney to prepare the PLR. Am I allowed to deduct this attorney bill on this years form 1041 based on code section 67(e) (deduction allowed if property not held in trust) or any other code section? Or is there something else I could do with the attrny fees or IRS PLR fees?

Thank you
Click to expand...
I think that you are going to have to consult a local tax professional.

There is a chance that someone here may have recently researched that and may be willing/able to provide the answer.

But odds are that is a question that requires research, and during this time of year most of us aren't willing to do that for free...we just don't have the time.
 
G

golfeveryday87

Junior Member
attorney fees for PLR

Thank you for your response. I am just hoping that somebody has looked into the issue of deducting attorney fees for writing the PLR's.
 
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