NOTES 693 Tax Lawyer, Vol. 54, No. 3 NOTE FEES PAID BY TRUSTEES FOR INVESTMENT STRATEGY ADVICE AND MANAGEMENT SERVICES ARE NOT DEDUCTIBLE UNDER SECTION 67(e)(1): MELLON BANK, N.A. V. UNITED STATES In Mellon Bank, N.A. v. United States,1 the Court of Federal Claims held that fees paid by trustees to investment advisors, accountants, tax preparation servicces and management services were subject to the two-percent floor in section 67(a) if those same costs would have been incurred had the funds not...