Emerald Corporation is required to change its method of accounting for Federal income tax purposes The change will require an adjustment to income to be made over three tax periods Jonas, the sole shareholder of Emerald Corporation, wants to better understand the implications of this adjustment for E P purposes, as he anticipates a distribution from Emerald in the current year Prepare a memo for your firm's client files describing the results of your research Facts Succinctly state the facts relevant to the resolution of the taxpayer's issue Doing so involves reviewing the facts to include only those relevant to answering the question(s) at issue in your memorandum Question Presented State the question or questions your memorandum seeks to answer If possible, present it in a single sentence (e g , Will Mr Smith have to include the value of the property in income ) Most (if not all) of the memoranda you will be assigned will present a single, overarching question Granted, there may be multiple issues that you have to analyze to answer this question, but all of them go toward answering the larger question such as whether the taxpayer has to include the value of some property in income Short Answer State the answer to the Question(s) Presented as clearly and succinctly as possible again, preferably in a single sentence (For example, your Short Answer to the Question Presented answer above might be, Mr Smith will have to include the value of the property in income ) Analysis This is the substantive portion of your memorandum and is worth the majority of the points on the assignment It is where you present all of the analysis that is required to support your Short Answer In performing your analysis, you should use the general IRAC approach you have learned and utilized to date, although you will not have specific sections within the Analysis listed as Issue, Rule, Analysis, and Conclusion Once you have identified the issue or issues that you have to resolve to answer the Short Answer, you will need to perform tax research to identify tax authorities to establish the controlling rule that resolves that issues Your analysis for each of these issues should review these authorities and then apply them to the facts of the case to draw conclusions Compose a 2 page length, double spaced, 12 font memo showing proper tax law citation and references Note Please remember that this memo must be in your own words except for properly cited rules or quotes

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Emerald Corporation is required to change its method of accounting for Federal income tax purposes. The change will require an adjustment to income to be

Emerald Corporation is required to change its method of accounting for Federal income tax purposes. The change will require an adjustment to income to be made over three tax periods. Jonas, the sole shareholder of Emerald Corporation, wants to better understand the implications of this adjustment for E & P purposes, as he anticipates a distribution from Emerald in the current year. Prepare a memo for your firm's client files describing the results of your research.

1. Facts:Succinctly state the facts relevant to the resolution of the taxpayer's issue. Doing so involves reviewing the facts to include only those relevant to answering the question(s) at issue in your memorandum.
2. Question Presented:State the question or questions your memorandum seeks to answer. If possible, present it in a single sentence (e.g., "Will Mr. Smith have to include the value of the property in income?"). Most (if not all) of the memoranda you will be assigned will present a single, overarching question. Granted, there may be multiple issues that you have to analyze to answer this question, but all of them go toward answering the larger question --such as whether the taxpayer has to include the value of some property in income.
3. Short Answer:State the answer to the "Question(s) Presented" as clearly and succinctly as possible --again, preferably in a single sentence. (For example, your "Short Answer" to the "Question Presented" answer above might be, "Mr. Smith will have to include the value of the property in income.")
4. Analysis:This is the substantive portion of your memorandum and is worth the majority of the points on the assignment. It is where you present all of the analysis that is required to support your "Short Answer." In performing your analysis, you should use the general "IRAC" approach you have learned and utilized to date, although you will not have specific sections within the "Analysis" listed as "Issue," "Rule," "Analysis," and "Conclusion." Once you have identified the issue or issues that you have to resolve to answer the "Short Answer," you will need to perform tax research to identify tax authorities to establish the controlling "rule" that resolves that issues. Your analysis for each of these issues should review these authorities and then apply them to the facts of the case to draw conclusions.
Compose a 2 page length, double-spaced, 12 font memo showing proper tax law citation and references.Note:Please remember that this memo must be in your own words except for properly cited rules or quotes.