Prepare a $2$ to $3$ page memo for your tax partner. Your response should be in a format of a file

memorandum $($see outline below$).$ You should include citations to the Internal Revenue Code

$($IRC$).$

The basic format for the memorandum is:

Memo header:

Facts: Summarize all relevant facts

Issues: In a question format or in whether or not sentence state:

Issue $1$

Issue $2$ etc.

Conclusions: Sentences stating conclusion$($s$),$ without including an in depth

analysis$/$explanation included in this section

Conclusion $1$

Conclusion $2$ etc.

Internal Revenue Code $($IRC$)$ Support: summarize$/$quote all IRC section$($s$)$

Analysis: an in depth written discussion of how the IRC section$($s$)$ as applied to the Facts

resulted in the Conclusion$($s$)$ with respect to each Issue$($s$)$

Facts

In $2022,$ Frank, who was the chief financial officer of Ford Motor Company $($Ford$),$ pled guilty to

embezzling $$100,000$ from Ford. Frank went on vacation to Las Vegas to play in a poker

tournament and paid $$100$ for his hotel room. Although he had no winnings from playing in the

poker tournament, he had $$1,000$ in gambling losses.

While Frank was in Las Vegas, a tornado destroyed his home causing a casualty loss of $$200,000,$

which was not covered by his homeowner$$s insurance. Fortunately, the president declared the area

where the tornado occurred a federally declared disaster area. Upon the death of his mother, Frank

received $$10,000$ in life insurance proceeds.

Your tax partner has asked you to write a file memo about what amounts Frank has to include as

income and what amounts he can deduct on his $2022$ US federal income tax return.