can you help me with this tax research assignment please?

tax Brief Instructions 1. Write the title of the case and the case citation. The title of the case is structured as: petitioner's name (the person bringing the suit) v. respondent's name. For instance, "Jones v. Commissioner of Internal Revenue". The case citation is a series of numbers and descriptors used to retrieve the case, such as "2004 WL 29302 (U.S. Tax Ct.)". This citation states that the case occurred in 2004 and can be found using Westlaw at case 29302, and that it is a United States Tax Court case. 2. Summarize the facts of the case. The facts of any case, particularly a Tax Court case, can be very long and contain some nonessential information. Summarize the facts by writing down only the pertinent data: the names, dates and actions that ultimately determine how the case turns out. 3. State the issue or issues that are presented in the case. These issues are what make the case important enough for the Tax Court to hear it. Usually the issue statement can be formulated by beginning with the word "whether" and then stating the question to be determined in the case, such as "Whether a person realizes income when she sold her house for $250,000 and she has a cost basis in the house of $240,000." Another possible format is the "UnderDoes-When" format, stated as: "Under the Tax Code, does a person realize income when she sold her house for $250,000 and she has a cost basis in the house of $240,000." 4. State the court's holding. The court's holding is the decision that the court made, such as: "The petitioner realized an income of $10,000 when she sold her house for $250,000 and she had a cost basis in the house of $240,000." 5. List the rules of law. There are rules of law that the Tax Court uses in arriving at its holding. List these rules in your case brief. The rules are often either statutes, such as "gross income means all income from whatever source derived," which is the Internal Revenue Code section 61; or the holding from previous case law, which will be accompanied by a case citation. 6. Summarize the court's rationale. It is important for law students to understand why the Tax Court arrived at the decision that it did, and to do this, they should write a brief summary of the court's rationale. This research assignment will include a client letter with a seperate reference page attached. The facts for this assignment are as follow: During 2014, the Hills were employed by Hogwarts State University. Dr. Hill taught math and communications classes as an adjunct professor, and Mrs. Hill was employed as a campus librarian. Dr. Hill is highly educatedhe holds a doctorate in communication. As he explained to you, individuals holding such terminal degrees bear a lifelong burden of \"developing knowledge, finding knowledge, exploring, [and] essentially selfeducating\". Dr. Hill is seeking a new tax preparer, doing some comparison shopping, and has come to you with the following unreimbursed employee business expenses: Home Internet expenses of $945 because the Internet access contributed to increasing his \"general knowledge\" and that Mrs. Hill was ill and required the use of the Internet to work from home. Cellular phone expenses of $2,288, they have copies of their statements showing the paid the expenses. Computer equipment expenses of $1,719 which Dr. Hill claims is necessary for their jobs as education and library professionals. Professional library consisting of books, CDs, and DVDs at a cost of $1,956 which according to Dr. Hill are expenses ordinary and necessary to their jobs because they must expand their \"general knowledge\". DirecTV subscription expenses of $2,258.87 which was necessary to expand their general knowledge. Dr. Hill wants your opinion on these unreimbursed employee expenses to help him decide which tax preparer engage. Tax research helpful information Section 162 262(a) 274(d) 280 F Fessey v. Commissioner, T.C. Memo. 2010-191 Pistoresi v. Commissioner, 24 T.C. Memo.1999-39 Tanzi v. Commissioner, T.C. Memo. Your research assignment will be graded using the following criteria: 1. Recognition of the important facts and issues 2. Correct conclusion 3. Proper citation of relevant sources 4. Format, Spelling & Grammar 5. Clarity of writing