Imagine that the Internal Revenue Service (IRS) has selected your client for an audit. Your client and the IRS disagree about the amount of tax revenue owed. You agree with your client's position. You must provide a defense for the client that requires you to research the issues in order to render an educated opinion on a course of action for your client. Note:You may create/or make all necessary assumptions needed forthe completion of this assignment.

Part 1

Construct a case and prepare defensible strategy for the client by using the six (6) steps in the tax research process. Propose how each of the steps provides support for the client's position.

Part 2:

Prepare tax memo for your client that:

Creates a fact-based argument that you plan to propose to the client as a defense of his /her position with the IRS.