please help to solve the attached file

In 2020, Bob a in Lu Vege wiff totaling stoo,ooo. On I , 2020 , Bob Hod uquid a Lu Vege fu $660,000 afte Hawaii. o f_md this , he , &atuing fint by a simple fu 9 The totaling 000, by a mm-gage the m'ly Fint Buk the mutgage md $200 his E the Notably, while fmily the Emii st$mLat&i that first wifi uy appliel to principal a of on I , 2022: MY lost his job to of a-tificial (A1). At the I , 2023 , Hwaii biddu ft at "No Rm CRS) Fom 10-98, to Hodfrm '023 Mr. Hod a 000 fir 2023, depite the of F 1098 _ The [RS The IRS that sin the bid "did to Hmii Bn mntgags to at of sai8_ " On I 2024 , the Buk the to third puty fu $500,000. The [RS alleged civil by Hod_ A to RS a dvil .in_atim ofhiQ 2014 2016 to [RS a aiminl into his 2014 2018 tu As a of Hod m-icted of to a tam. In 2024 at [RS anizistative apl Mr. Hod pted a Mr. Hod c ud ttified mat he s md guding tu INSTRUCTIONS: N'fr_ Hod is a one of which relates to a penalty. (To ensure you address the three most important issues you may identify a maximum of five issues). Each issue must include relevant critical facts and precisely where in the code each issue arises. Use the following subheadings which are expected in a tax research memo. Use the followmg order: Facts, Issues, Conclusions, List of Applicable Law, Discussion ofLaw, and Application. For the revised memo must discuss and apply the three most relevant court cases. (To ensure you address the three most important court cases you may discuss and apply a maximum of five court cases). Only one court case should focus on the relevant penalty as applied to your client's situation. The mitial follmd by a rate. Both by a the pmpUty $400,000 Hod defulted on in 2022 to job 3200,OOO The tught pzowty E 00, 000 2023 Mr. Hod a SSO,OOO for 2023 1098 The IRS ud alleged civil b Qd on Rod' s put for Prorry CRC 163 Hod mutgage in of (2023) devite covuing of Sale ud Debt URC SS 1001 & How sale two 1m, for debt Civil Fnud (IRC S 660): c u IRS its civil t Hod' s put tu his BO at appel? Luy 2 of ud debt hue tu 3. The IRS might civil b OL put his of in tu L t of Appliable L Code (IRC) 163 (g) : IRC 1001: of of Gain or IRC 108: of oflLdeb.te Lnc IRC S of of Law 1m e 1 : Mortgage Intmt fu F Property (IRC S 163(g)) IRC to dedut qulified dedutibllity of in o f for the yeu of limited to the intt up to date Mr. Ho&y zauires: to Calulating up to Juno' I 2023 , date. Ime 2: of F Sale Debt Dihuge URC SS 1001 & 108) EOO,OOO pzxds to two The allotion the ud state (1400:000) might be a of IRC S 108 debt from may apply if di"huged debt E by CRC 3: Civil mud 6663) IRS civil on Mr. gut tu of prwf fraud ud which i. "me likely Mr. claim of of mht it fu IRS to to APPLICATION fict., Mz Hod not able to clann mortgage 2023_ The in of debt , Mz Hod IRC The IRS a civil if it prove on Rod' s