Assume you work for an accounting firm and the tax partner in charge has requested a professional memo regarding a tax issue. The tax partner desires you follow the five-step process as outlined in the article, "Optimize Your Firm's Tax Research Methodology: A Practical Guide to Perfecting Your Tax Research Techniques and Achieving Sustainable Tax Return Filing Positions," as provided in the topic Resources. Your response should be at least 500 words, but it should not exceed 3 pages. You may use the "Memo Template" resource for this assignment.

Allison is part owner of a law firm, Canyon Law Offices, LLP. Her firm services sports teams and high-wealth individuals, including professional athletes. As part of her job, she entertains clients and travels to their location, where she spends money on meals and entertainment. During her travels she incurs expenses for meals, hotel, airfare, transportation, and other miscellaneous items associated with travel. Additionally, she pays for a luxury box for the local professional basketball team and has season tickets to the local professional football team. Allison tells you, her CPA, that she spent $45,000 on meals and entertainment (including the luxury box and season tickets) during the prior year. She did not keep detailed receipts for each meeting or event, but can recall who she was with, the topics discussed, and the location of each meeting.

Prepare a tax memo for Allison regarding deductibility of meals and entertainment expenses. To support your conclusion, include at least two authoritative sources, such as the Code, Revenue rulings, or Treasury regulations, and at least one tax case specifically regarding meals and entertainment. Include a discussion of the AICPA's Statements on Standards for Tax Services with regard to your responsibilities as a tax professional. Include any other relevant authoritative sources.

Please Cite any sources used. Thank you!