Internal Revenue Service
Revenue Ruling

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 Rev. Rul. 55-23

1955-1 C.B. 275

Sec. 212

Full Text

Rev. Rul. 55-23

Where a subscriber to a sponsored investment plan pays a custody fee, as distinguished from a `creation' fee, to the sponsor and custodian of the plan for services rendered in making investments and keeping necessary records, the fee, pursuant to Revenue Ruling 3, C.B. 1953-1, 37, is deductible annually as a nonbusiness expense under section 23(a)(2) of the Internal Revenue Code of 1939 and the subscriber-taxpayer has no election to treat the fee as a capital expenditure