In Bingham v. Commissioner of Internal Revenue, 325 U.S. 365, 65 S.Ct. 1232 (1945), counsel fees, incurred partly in contesting an income tax deficiency assessed against the trust and partly in winding up the trust, were held to be deductible under 23(a) (2), Internal Revenue Code. The court said, 325 U.S. at page 376, 65 S.Ct. at page 1238: " the trust, a taxable entity like a business, may deduct litigation expenses when they are directly connected with or proximately result from the enterprise - the management of property held for production of income."