State a conclusion and list primary authorities.

The memo should contain the following five parts: a brief discussion of the facts, the specific issue(s) addressed, appropriate citations to authority, a conclusion for each issue, and an analysis of the authorities and how the authority supports your conclusion. You must cite appropriate primary authority (e.g. Internal Revenue Code of 1986 as amended, regulations, court cases, revenue rulings, private letter rulings) Tax services' commentaries such as RIA are not primary authority but they reference and include primary authority such as the Internal Revenue Code and court cases. Explanations from tax services or IRS publications cannot be used to support your answer. Be sure to check the citator for new developments. (When you have a court case open, there is a button at the top of the case labeled "citator." The citator will lead you to court cases that have cited the case you are viewing and indicate whether or not the case agreed with the original case that was cited.) This memo should appear professional (neatly typed, correct grammar and spelling). There is a good example of a research memo on page 2-20 of the textbook. Attach copies of all relevant authority and highlight the portion that applies to the tax problem. Please do this by cutting and pasting from the Internal Revenue Code, Regulations, Tax cases, etc. and placing the authority immediately after your memo on page 2 or 3 and additional pages if needed. Use the highlighter in Word or an actual highlighter to emphasize the relevant sections. It is not