Prepare a tax research memo addressing the question that has been raised. You will need to support your conclusion using primary sources of tax law. Your textbook is NOT primary authority nor are IRS Publications.

QUESTION

Prepare a tax research memo addressing the question that has been raised.

You will need to support your conclusion using primary sources of tax law. Your textbook is NOT

primary authority nor are IRS Publications.

You must use proper citation form in your memo (see Chapter 2 for help with citation form). The form

for this communication should be professional and in the form of a tax research memo (examples

posted on Blackboard and a similar example in your textbook). Do yourself a favor and look at the

grading rubric before you submit.

This memo should be whatever length you feel is appropriate to resolve the issues. We do NOT use a

bibliography or list of references in a tax research memo. You will see that citations are within the text

of the document in the example. Once a court case has been cited in full, it can be referred to using

simply the name in italics.

QUESTION

[Your Name]
[Your Address]
[City, State, ZIP Code]
[Date]

[Client Name]
[Client Address]
[City, State, ZIP Code]

Subject: Tax Research Memo – [Issue]

Dear [Client Name],

I am writing this memo to provide you with an analysis and conclusion regarding the tax issue raised. The issue at hand is [briefly state the issue].

Facts:
[Provide a concise summary of the relevant facts that pertain to the issue]

Issue:
The primary issue to be addressed is whether [state the specific question(s) that need(s) to be answered]

Conclusion:
After conducting extensive research and analyzing the applicable tax laws and regulations, I have reached the following conclusion:

[Present your conclusion in a clear and concise manner, supported by primary sources of tax law. Provide a brief explanation of your reasoning.]

Supporting Analysis:
[Provide a detailed analysis of the relevant tax laws, regulations, and court cases that support your conclusion. Use proper citation form within the text of the memo to reference the primary sources of tax law.]

[Present your analysis in a logical and organized manner, addressing each relevant aspect of the issue. Use headings and subheadings if necessary to enhance clarity and structure.]

Recommendation:
Based on the above analysis, I recommend [state your recommended course of action or further steps to be taken].

Please note that this memorandum represents my professional opinion based on the information and sources available at the time of writing. Tax laws and regulations may change over time, and further analysis may be necessary as new developments arise.

If you have any questions or require further clarification, please do not hesitate to contact me. I am here to assist you with any tax-related matters.

Sincerely,

[Your Name]
[Your Title]
[Contact Information: Phone Number, Email Address]