Hi, so on Jan 20, 2017 you answered a question that looked like this:

"Practicing Research to Writing Writing assignment 1: 1. Review the Pennsylvania Writing Assessment Domain Scoring Guide available to you in your course handouts in Canvas; noting the definition of each domain and the scaling of quality in each domain. Observe how your grading rubric ties into the PA Writing Assessment Domain Scoring Guide. Please keep in mind the standard of care expected of you as a tax professional. Every document you write should be written professionally (including tweets, text messages, emails, blogs, memos, letters, etc.). Why is that? Bottom line is you never know who will see what you write. Your boss, your future boss, your spouse, the newspaper, the courts if litigation ensues, are all examples of who might end up reading what you write, whether you intended the document for the audience or not. 2. Draft a brief, well written memorandum to your client in good format (See IRAC template) that answers this question: Can you sign the return with this tax position included or not? If you can sign the return incorporating that tax position, are there any corollary actions you should take? If you decide you cant, what should you advise your client/friend is an appropriate course of action? 3. Here your background information: You are a new manager and you brought in a $150,000 individual income tax engagement on a referral from a friend that is the tax director at a major client of your firm. Your quality reviewer seems to have some issues with deducting the charitable contribution of the development rights (qualified conservation contribution) associated with the real estate near a golf course the new client owns. Your client has valued those rights at $39,000,000 and he wants to deduct the full amount from his income in the year you are preparing the return. Due to a repurchase clause in the contribution agreement, your firms quality reviewer says the clients tax return position has a likelihood of surviving IRS examination of a 1 in 4 chance; rising at best to a 35% chance of surviving a challenge by the IRS. The fact that this new client is contemplating running for President of the United States has further raised the reviewers anxiety. 4. Additional guidance to consider for your memorandum: Your memorandum must be in good form (Use IRAC template as a format.) that identifies what the issues are and how you should address those issue(s) for your client: Using the facts and circumstances noted above, your memorandum should address (at a minimum) a. A recitation of your facts and circumstances and the question(s) as you have clarified them. Additionally, you must cite the relevant authorities using Bluebook citation method. You should analyze those authorities for the purpose of applying those authorities to answer your question(s), and conclude with a clear statement of what professional standards require you to Penn State Accounting 405 Tax 1, Spring 2017 do. You conclusions should also provide your client with a recommended course of action. b. Edit your memo using the PA Writing Assessment Domains Scoring Guide. When you are satisfied you have 4 levels of writing in each domain, submit your memorandum and table of authorities to the drop box. Save your file using this nomenclature: yourlastname405ethicsmemoSP16.docx c. You must complete a table of authorities (TOA) (see the template under Student Resources) as a means to document and analyze the authorities you research. You are expected to document your thinking in the TOA in such a fashion that drafting your memorandum is largely a cut and paste job from your TOA. Remember how to use the TOA: i. Complete the heading information; especially the keywords you plan to use to search the BNA, CCH Intelliconnect, RIA Checkpoint Data Base or other sources. Consider keywords like substantial and authority, more likely than not or substantial understatement. ii. Put the information necessary to prepare a complete citation using Harvard Legal (Bluebook) citation methods (See the PS Library system web page for help.) in the Citation column. iii. Citable material is documented in the Research/Facts/Observation/Legal Precedent column, iv. Your thinking and analysis (What does it mean to your research question?) is documented in the Application column, and v. Your instructor will be your reviewer for this assignment and he or she will check your citations and thinking in the TOA as they think appropriate. vi. This project is not long enough to require a detailed outline so do not worry about putting outline references in the Reference column. d. At a minimum your research and analysis should include a review and consideration of: i. IRC Section 6662 and specifically Treasury Regulation 1.6662-4(d) (What penalties may be assessed against your client.) ii. IRC Sections 6694 and 6695 (What penalties might be assessed against you or your firm.) iii. AICPA SSTS #1 iv. Since you are located in Pennsylvania, the PA CPA Act. v. While ASC 740 applies to your client, you can assume the financial statements are already finished and issued. You therefore do not need to address the financial reporting issues. e. When you have finished your memo and edited it, please submit your memo to the drop box using the above protocol/nomenclature in 4b, then submit your TOA. Use this nomenclature for the TOA file: yourlastname405TOASP17.docx. Page 2 Penn State Accounting 405 Tax 1, Spring 2017 5. Your submissions will be graded using the published rubric. Keep in mind the CPA firm leveraging of expertise and keep your memorandum to a minimum. 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You submitted a very good Table of Authorities, but I was just wondering how you would answer question #2. What route would you take when advising the client in the situation presented and concluding from your TOA.