Please use the IRAC method to present the case Mad Auto Wrecking, Inc. v. Commissioner, TC Memo 1995-153 , Code Sec(s) 162.

(Issue, Rule, Analysis and Conclusion (IRAC)) Issue: What is the question that the court had to decide (such as, are certain particular expenses deductible, is certain income taxable, or whatever is in dispute. Be as precise as possible. Rule(s): What are the primary areas of law (such as specific IRC Code sections, Treasury Regulations, other court cases or other laws (such as Revenue Rulings, Revenue Procedures, etc.) that the court used to come up with its decision in the case. If there are large number of other cases cited in your case, you can just reference one or two cases that you think the court focused on the most in the ultimate decision in your case. You do not have to list all of the cases.

Analysis: First, go over just the pertinent facts of the case (you do not need to list every single fact) and then describe how the court applied the rules above to the pertinent facts of the case. Conclusion: What was the ultimate decision by the court? Did they rule in favor of the taxpayer? The IRS? And what was their specific ruling (for example, certain income tax taxable, etc.) For all sections above (Issue, Rule, Analysis and Conclusion), please do not simply read each word directly from the case. provide an explanation- in a way that is easier to understand for someone hearing