Facts: In this section, you summarize the facts about the transaction or events that are reievant and material to the tax questions being asked. Frame them as precisely and succinctly as possible, and write them so that they can be understood by someone who has no knowiedge of the underlying facts. Issues: This is a succinct question that you are trying to answer or resolve in the memorandum. Analysis: This section contains all of the substantive analysis that you needed to perform in order to come to reach a conclusion on the issue presented. it discusses, in logical order, the various tax authorities to establish the tax rule or rules that apply to the fact pattern given. This includes such efforts as an analysis of the facts of these other cases and the language of the applicable Code section(s) at issue. Once the rules are established, it then applies those rules to the facts in the case. Conclusions: This section provides the answer to the taxpayer's inquiry aiong with any tax planning suggestions for future impiementation