Please see the attached Research Assignment and needed format.

Your Name RESEARCH CASE FORMAT DATE Recipient Name Recipient Address RE: Subject Matter/Broad Issue Dear Mr. or Ms. [Recipient]: The IRS uses the FIRAC format when preparing cases. We will use the same format. I. FACTS: Provide a brief statement of the facts that are provided to you. Highlight only the important facts and do not just copy and paste the facts from the assignment. II. ISSUE: A clear statement of the issues. The issue is the problem(s) you are solving for the client. You may use specific facts to clarify the issue. For example, \"Bob took five flights for personal pleasure and one flight for business. Can Bob deduct the personal pleasure flights?\" III. RULE OF LAW: A review of the tax authorities A. Legislative Authority- The IRS Code B. Administrative Authority- Regulations, Revenue Rulings C. Judicial Authority-Court Cases Make sure you give a summary of all three sources of tax authority as it pertains to the issues involved. If a specific source contains no relevant information, indicate this fact. Explain the authorities, do not use excessive quotation. IV. ANALYSIS/ARGUMENT: Provide the analysis of the authorities as related to the facts of the case. This should be the longest section of the paper. Please walk me through how the law applies to the facts. Do not just make conclusory statements with no analysis. Every conclusion you reach should be supported with facts and law. V. CONCLUSION: Provide your conclusion as to the recommended treatment. Briefly summarize your analysis and the conclusion reached. VI. CITATOR: Select at least one case and look it up in the Citator. Give a brief summary of what has happened to the case since it was rendered. What was the original court of jurisdiction? Was it appealed? Have other cases made reference to the case. If so, were the references favorable or unfavorable? Accounting 411 Fall Semester 2017 Tax Research Case Facts Walter White, CEO of Blue Hard Candy Company, and his wife, Skylar, entered into a prenuptial agreement. According to the prenuptial agreement, Walter granted Skylar a life estate in their residence so long as Skylar did not remarry, and if she did remarry the house would transfer outright to Walter's son Walt Jr. also known as Flynn. In other words, Skylar could live in their house so long as she doesn't remarry but if she did then Walt Jr. would own the house. Walter White also had a Last Will and Testament that completely disinherited Skylar and left her only with the life estate in their residence according to the prenuptial agreement. Out of nowhere, Walter dies unexpectedly and has a huge estate from the success of his Blue Hard Candy Company. Skylar decides to hire legal representation and challenges the validity of the prenuptial agreement and contests the will. Walter's long-time lawyer, Saul Goodman, is representing Walter's Estate. Saul, inexperienced in the nuances of tax law, decides to just pay Skylar a settlement payment to settle all of her claims to the estate and, upon receiving the settlement payment, Skylar drops all claims against the estate. Skylar agrees to the arrangement. Saul believes he is in the clear and goes ahead and prepares the estate tax return for Walter's Estate. Walter has a rather large estate so Walter's Estate ends up paying some estate tax. Saul, again, inexperienced in tax law, just assumes that the settlement payment made to Skylar qualifies for the marital deduction. On Walter's Estate Tax Return, Saul reduce the size of Walter's Estate by the amount paid to Skylar which substantially reduces the amount of Walter's Estate. Then, Saul files Walter's Estate Tax Return. Today, you receive a call from Saul Goodman. Saul is nervous and scared. He tells you that the IRS audited Walter's Estate Tax Return and is questioning whether to allow the marital deduction for the settlement payment made to Skylar. Saul, feeling in over his head, called your CPA firm to help him solve this tax problem. Saul mentioned he had some guy who sells vacuums on the other line in case things went South... But, you reassure him that you can give him an answer and that everything will be alright. Assignment Write a letter to Saul in the required memo format with your answers to the ability of Walter's Estate to utilize the marital deduction for the settlement payment made to Skylar. Saul's address is The Law Offices of Saul Goodman, LLC, 1234 Inflatable Statue of Liberty Road, Albuquerque, New Mexico 87101. Please submit the assignment on Blackboard no later than 11:55pm Sunday, September 10, 2017