7. Austin Towers is a convicted former spy for the former Soviet Union. Austin received a

communication from a Soviet agent that $2 million had been set aside for him in an account

upon which he would be able to draw. Austin was told that the money was being held by the

Soviet Union, rather than in an independent of third-party bank or institution, on the petitioners

behalf. Over the next few years, Austin drew approximately $1 million from the account. During

that period, Austin filed annual tax returns with his wife showing taxable income of

approximately $65,000 per year. Conduct appropriate research to determine Austins tax liability

for the $1 million in spy fees.

Prepare (in good form) a research memorandum to the file.