Question juridique clé
Whether opaque banking package fees are deductible as necessary third-party asset-management costs.
Solution extraite
No. Only the identifiable payment-transaction fees could in principle be deducted; the package as a whole was mostly for non-deductible banking services unrelated to asset management.
Motifs extraits
Deductible management costs must be shown as necessary expenses for preserving income-producing assets. The package bundled many services unrelated to asset management, and the taxpayer did not break down the annual fee into deductible and non-deductible components.