In Knight v. Commissioner, the Supreme Court recently resolved a pronounced circuit split and held that investment advisory fees are miscellaneous itemized deductions under § 67 of the Internal Revenue Code and do not fall under the exception provided for trusts and estates in § 67(e)(1). Therefore, investment advisory fees are subject to the same limitations and disallowances as those fees incurred by individuals. This Note analyzes the Supreme Court’s approach to this question and concludes that despite its problems, the Supreme Court’s construction of the statute was the only reasonable interpretation.