Upon looking thru pub 529 "Misc Deductions" and I am going to conclude no, not even subject to 2% rule though the fees were to get personal credit card debt cancelled which then generates a form 1099-C, taxable income unless they can prove negative net worth.
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Your assumption
I believe would be correct based on Pub 529
Personal in nature - so no deduction either on Schedule A or possibly to reduce the amount of debt cancelled.
Here is a link (old though it might be back to 2009 - I would think still valid)
http://taxlaw.typepad.com/tax_law/20...missioner.html
Sandy
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