relevant Code provisions, the case law does not provide a consistent set of criteria on which ataxpayer can rely. Justice Cardozo's statement remains appropriate: "One struggles in vain forany verbal formula that will supply a ready touchstone If it does, the expenditure is capitalTimothy Elton...
Under the Advisers Act, an “investment adviser” is generally defined as a person who “engages in the business of advising others” regarding securities. The Advisers Act is silent on the treatment of internal directors, managers, officers and employees (collectively,Internal Managers) of investmen...