Can someone help me with a tax research memo homework assignment?

Tax Research Memo Facts Mia owns 100 percent (100,000 shares) of the stock of Acme Corporation. She is also the president of Acme. Acme makes candy and is a fast growing company. Due to its success, the company plans to build a new manufacturing facility. Mia currently owns a parcel of land with her brother Enzo. They own the land as tenants in common, which means that each of them holds an undivided ownership interest in the property and neither one has the right to dispose of the property without the consent of the other. The land is an ideal location for building the new manufacturing facility. Mia and Enzo each own a 50 percent interest in the land, which is worth $1.8 million. Mia and Enzo each have a basis in their 50 percent interest in the land of $200,000. Mia and Enzo plan to transfer the land to Acme and in exchange each will receive 900 shares of newly-issued Acme stock. Acme stock is worth $1,000 per share, before and after the transaction. Thus, the Acme shares that Mia owns prior to the transaction are worth $100 million. Required Context. Assume you are a first-year tax associate at a CPA firm that serves as the tax advisor for Mia and Acme. Emma, who is the tax manager on the Acme account, has asked you to analyze the federal income tax consequences of the proposed transaction. The deliverable on this project is a research memo, writing in the FIRAC format (see below). To help get you off to a good start, Emma provides you with the following guidance. \"Obviously, the operative provision is Section 351. Make sure you also look at the regulations under 351. I worked on a complex 351 transaction last year, and I recall that a revenue procedure issued in 1977 provides some important safe harbor rules. Finally, although the transfer of land to Acme in exchange for stock is a single transaction, please keep in mind that Mia and Enzo are separate taxpayers and the issues they face may be different.\" Hints. See IRC Secs. 351(a) and 368(c), Treas. Reg. 1.351-1(a)(1)(ii), and Rev. Proc. 77-37, Sec. 3.07. Citation style. Use the following citation style for the Code, regulations, and revenue procedures: IRC Sec. 904(d)(4), Treas. Reg. 1.168(k), Rev. Rul. 99-6. This is an appropriate style when you are writing a memo for another tax expert. Individual assignment. The research memo is an individual assignment. It is not a group project. You must perform your own analysis and write up your own solution. How to submit. Upload a PDF file containing your memo to the course website. Use the following file naming convention: \"TAX 6105_Memo_Last name_First name.\" 1 Format of memo. Use the following format for the memo. For the Facts, you can merely insert the facts presented above. See below for guidance regarding other sections of the memo. To: From: Date: Subject: [reader's name] [your name] [current date] [what the memo is about] Facts Issue Rules Conclusion Analysis The memo must be single-spaced, have one-inch margins, and typed using Times New Roman 12-point font. The maximum length is two pages. Tips on How to Write a Good Tax Research Memo Facts - Write the facts in a simple, direct narrative. Organize the facts in a logical manner so the reader can check them for accuracy and completeness. Restrict the facts to those affecting the outcome for the client. Issues - The issues are usually expressed in a brief question form as if they were to be answered in the conclusion(s) section. Use the correct tax terminology. If possible, write questions that have a yes or no answer. You may also wish to number the issues so the reader can refer to them more easily in the conclusion and analysis sections. Rules - Create a list of the authorities (Code Section, Regulation, court case, etc.) that are critical to the court's ruling. Do not mention peripheral or extraneous authorities. Conclusions - Write the conclusion(s) as briefly as the issues, stating them as if they answered the questions in the issues section. If you number the issues, number the conclusions to correspond. If the issue is a question that has a yes or no answer, begin the conclusion with \"Yes\" or \"No,\" and elaborate with \"because...\" from there. Remember that the issues and conclusions set the stage for the logical analysis that follows. Analysis - This is the most important part of your memo because it describes how you arrived at your conclusion. The Analysis combines all parts of the memo rolled into one, describing the application of the rules to the facts of the case to answer the issues raised. Make sure you describe your reasoning in a step-by-step fashion, and do not leave any gaps in your logic. Begin your argument by analyzing how the statute applies in the given fact situation. If necessary to support your conclusion, expand your argument to include an analysis of applicable Treasury Regulations. Finally, refer as necessary to an analysis of other administrative authority or case law. The Analysis is usually the longest part of the brief, followed by the Facts. In contrast, if there is only one issue, the Issues and Conclusions may each be just a sentence long. 2