I really need help asap with this tax research memo assignment (in pdf) attached!! I also uploaded an example of the tax memorandum format needed. https://fiu.blackboard.com/bbcswebdav/pid-3370761-dt-content-rid-33153401_1/xid-33153401_1 Please just to be safe, I am asking you if you can make sure its formatted as a tax memo listing of course the "Facts", then however many "Issue and Conclusions #1, 2" (etc), and lastly the "Analysis" for each "Issue and Conclusion". The writing assignments will be graded based on grammar, style of writing, logical development of ideas, critical thinking skills, and technical accuracy of the analysis and conclusions, using a rubric which will be found along with the assignment. Examples of file memoranda can be found at the M. Tx. Writing Website located at M. Tx. Writing Website .

Panther\tCorporation Ally,\tBettina\tand\tCarly\tare\tsisters\tand\teach\town\t100\tshares\tof\t300\tshares outstanding\tof\tPanther\tCorporation. They\thave\tenjoyed\trunning\tthe\tbusiness together\tfor\tseveral\tyears\tand\thave\tbeen\tsuccessful. Ally\tis\tgetting\tmarried\tand moving\tto\tCalifornia. She\tfeels\tshe\tcan\tno\tlonger\tbe\tinvolved\tin\tthe\tbusiness\tand wants\tto\tsell\ther\tstock,\twhich\thas\ta\tbasis\tof\t$40,000\tand\ta\tFMV\tof\t$100,000.\tEither Bettina\tand/or\tCarly\tcan\tpurchase\tAlly's\tshares\tor\tPanther\tcan\tredeem\tall\tof\tthem. Panther\thas\ta\t$220,000\tE\t&\tP\tbalance. Required: Prepare\ta\tmemorandum\tfor\tyour\tmanager\tcomparing\tthe\ttax consequences\tof\tthe\ttwo\toptions. Be\tsure\tto\tuse\tonly\tprimary\tauthority\tto\treference all\tyour\tconclusions. TO: File FROM: Alex Khanolipo RE: Mark, The Gambler FACTS: Mark, a professional gambler, is interested in buying a Condo in the city of Las Vegas, NV, considering this option solely on his income as a gambler, and while under the impression that the income provided is tax-free. ISSUE AND CONCLUSION 1 Is Mark's Income as a professional gambler tax deductible? Yes, Mark's gambling income is tax deductible ANALYSIS As Mark's occupation as a gambler is considered professional, according to Section 61, Gross income means all income from whatever source derived. As Mark's gambling is considered his main source of income, his activities as a gambler, including earning and losses, can be treated as derived from a business activity. To reinforce and emphasize this scenario, Rev. Rul. 54-339, 1954-2 C.B. 89, holds that gambling gains must be included in gross income. Also, the ruling in favor of Professional gambler, William Baxter, dictates that all earnings and losses as result of professional gambling, are to be taxable under a self employed status, as the skills necessary to successfully gamble were considered the \"tool of the trade\" Baxter v. United States, 633 F. Supp. 912, 861 U.S. Tax Cas. (CCH) paragr. 9284 (D. Nev. 1986) ISSUE AND CONCLUSION 2 How is professional gambling to be reported, and accounted? Gambling winnings and losses have aspects of both cash and accrual methods depending in the manner they were incurred, and they should be reported according to the law even if they are not within any specified limit ANALYSIS Even if the winnings did not require the filling of a W-2G form, as legitimate casinos require after the winnings of specified cash and prizes amounts under each gambling activity, all winnings and losses must be reported as taxable income. It is very important to keep the following at the moment of filing: 1- The deduction of gambling losses can only be applied to the extent of gambling winnings. 2- All gambling winning and losing sessions, are to be reported (either zero or greater) as gross receipts on the Schedule C 3- As professional gambling is considered under the self-employed status, any ordinary and necessary expense incurred in connection with the business of gambling can be deducted, such as travels, meals, etc. It is imperative for Mark to keep a written log of all his winnings and losses, along with any other relevant information such as, date, location, type of gaming, betting tickets, hotel bills, airline tickets, gas receipts, band deposits and withdrawals, and any other documentation that can prove your presence at the moment of the activity. A more organized and easier to track method for all gambling cash flows is to use a player's card. ISSUE AND CONCLUSION 3 Are there any penalties, and other issues that Mark could be facing for not reporting his earnings during previous years? For not reporting for annual taxes on income earned in previous years, Mark could be facing costly penalties, and other legal issues ANALYSIS According to Section 6651(a)(1), Failure to file the return by April 15th, or to obtain a six-month extension, for each month, or fraction of a month the return is late, the penalty will be equal to 5% of the next tax liability due for the year. Failure to fail is limited to a maximum of 25% of the outstanding tax. Section 6651(a)(2), mandates that failure to pay by April 15 th, a penalty of 0.5% will be added to the tax due for each month or fraction of the month the tax is outstanding, with the total penalty capped at 25%. CONCLUSION In the case of Mark The gambler, my professional advice is that before the purchase of this condo, the IRS should be contacted to commence an investigation with the purpose to settle any debt that could be pending, and that could affect his financial stance, making him unable to purchase a residence in the future. In regards, of purchasing the condo in Las Vegas, I believe that Las Vegas would be a great option as it is not only a city correlated with his profession, but also one of the seven states that do not collect any income taxes