“The Lender Case: Potential Avenue for Family Offices to Obtain Trade or Business Expense Deductions for Rendering Investment Management Services”
Lender Management, LLC v. Commissioner of Internal Revenue, T.C. Memo. 2017-246 (2017), provides family offices with a potential avenue for obtaining trade or business expense deductions under section 162 of the Internal Revenue Code in connection with rendering investment management services. In this Stroock Special Bulletin, we summarize the key aspects of the Lender case and address certain additional relevant considerations that were not discussed in that case but which could potentially be highly relevant in determining whether the result in Lender may be applied successfully in other family office contexts.