Letter to the IRS commenting on Proposed Treas. Reg. Section 1.67-4 & Notice 2008-32 which addresses the exception to the 2% of adjusted gross income floor on miscellaneous itemized deductions for certain costs that are paid or incurred in connection with the administration of an estate or a trust and requests comments concerning certain aspects of the Proposed Regulations, including the use of safe harbors and reasonable estimates by fiduciaries for unbundling fiduciary fees