1. Write Research Memorandum to convey your conclusions. .Make sure you prepare Research Memorandum - NOT a Client Letter.

2. The memo must be in proper form:

- A concise statement of pertinent facts.

- An identification of all tax issues (include list of authorities used).

- Your conclusions.

- A thorough discussion of the reasoning (analysis) upon which your conclusions are based.

- Citations, in proper form, to all primary authority relied on in reaching your conclusion,

e.g., code sections, reg. sections, court case, revenue ruling, etc.

3. Any primary authority discussed in your memorandum must be tied into the facts of this particular assignment. Do not merely recite the law without explicitly relating it to the facts at issue.

4. Secondary authority may NOT be cited in your memorandum. It should only be used to help you find relevant primary authority.

6. Your grade will be based on the following:

- How well you performed the research, e.g., did you locate, cite, and discuss the

relevant law.

- The quality of your written communication.

- The quality of your discussion of the issues.

- Your conclusions.

7. At a minimum, you should locate the following:

- Internal Revenue Code Section.

- Treasury Regulation.

- Revenue Ruling.

- Two different court cases (one must be at the Circuit Court level). The trial level

and appellate level of the same case do not count as two cases.

TAXPAYER INFORMATION

You are a senior manager of a large public accounting firm located in Des Moines, Iowa. One of your clients, Daniel Douglas, who is a minister of a local church in Des Moines, recently called you to research a tax question for him. Please research the issues relating to Daniel's question and write tax research memorandum. Daniel's question relates to the following:

Daniel is a minister who receives an annual salary of $16,000 in addition to the use of a church parsonage with an annual rental value of $6,000. Daniel accepted this minimal salary because he felt that was all the church could afford to pay. He plans to report these amounts on his income tax return but he is uncertain how to treat the cash gifts he receives from the members of his congregation. These gifts are made out of love and admiration for him.

During the year, the congregation developed a regular procedure for making gifts to him on special occasions. Approximately two weeks before each special occasion when Daniel was not present, the associate pastor announced before the service that those who wished to contribute to the special occasion gifts for Daniel could do so by placing cash in envelopes and giving them to the associate who would give them to the Daniel. Only cash was accepted to preserve anonymity. The church did not keep a record of the amounts given nor the contributors, but the Daniel estimates that these gifts amount to about $10,000 in the current year. How should Daniel treat these gifts?

tax research memo sample:

https://gofile.io/d/DcR2yV