prepare a memorandum (cite authorites)
able Window Help 97% AC371 Tax Research Memo Project 2 Fall 2020 - Compatibility Mode - Saved to my Mac Draw Design Layout References Mailings Review View Tell me Share es New.. 12 AA Aa A EME 21 T A. I U X X A2A Dictate Styles Styles Pane 1. Summary of the facts. 2. Statement of the issue(s). These are the questions which you are answering for your client. In some cases, a client may ask for assistance with more than one issue. Your memo should outline all of the relevant issues in this section. 3. Conclusions and recommendations to your client. You should briefly summarize the answer(s) to the issue(s) that you listed in part 2. Note that the rationale for the answers should be provided in the next section, as outlined below. 4. Technical analysis and support for your conclusions and recommendations. In this section, you should include the following, if the sources of tax law are relevant to your analysis (only some of the primary authorities listed may be applicable to your issue client situation): A. Discussion of relevant Internal Revenue Code provisions. These provisions will be more general in nature but, nonetheless, are important as they provide the basis for allowing the taxpayer to obtain the tax treatment you are recommending. The use of direct quotes is English (United States Focus 1135 words BE X1W MacBook Pro 000 da > able Window Help 97% AC371 Tax Research Memo Project 2 Fall 2020 - Compatibility Mode Saved to my Mac Draw Design Layout References Mailings Review View Tell me Share es New 12 ' ' Aav A 21 I Veb X X A LA IE Dictate Styles Styles Pane Sens the tax treatment you are recommending. The use of direct quotes is acceptable when you are listing the guidance contained in the relevant Internal Revenue Code provisions. B. Discussion of relevant Treasury Regulations, if any. The regulations will generally provide more specific guidance and examples related to the Internal Revenue Code provisions. C. Discussion of other relevant rulings, revenue procedures, notices, announcements, or other sources of administrative guidance provided by the Treasury Department and the IRS, if applicable. D. Discussion of court cases supporting your recommendation(s) to your client, if any. i. In your discussion of the cases, sparing use of direct quotes is acceptable. You must first explain the facts and decision in the court case and then explain how the findings relate to your taxpayer's situation. You should read the full text of the court case. E. Discussion of any other sources you located, including secondary authorities or other IRS publications. See Exhibit 2-5 in Chapter 2 of the textbook for a list of the proper citation formats for achtsfeta administrative and indicial authorit Vancould utilia mila Engish (United States Focus 1135 words DE 21 09XW MacBook Pro Assignment You are functioning in the role of tax advisor to the client in the assigned research project. You should prepare a memorandum which summarizes your research and conclusions related to the tax issue(s) presented by your client for consideration. The issue for consideration is outlined at the end of this document. While you may discuss the issues presented by your client and the database search process with other members of your class, each individual should prepare his/her own technical memorandum and should not receive any assistance from other class members with respect to the written analysis contained in the memorandum. able Window Help 97% AC371 Tax Research Memo Project 2 Fall 2020 - Compatibility Mode - Saved to my Mac Draw Design Layout References Mailings Review View Tell me Share es New.. 12 AA Aa A EME 21 T A. I U X X A2A Dictate Styles Styles Pane 1. Summary of the facts. 2. Statement of the issue(s). These are the questions which you are answering for your client. In some cases, a client may ask for assistance with more than one issue. Your memo should outline all of the relevant issues in this section. 3. Conclusions and recommendations to your client. You should briefly summarize the answer(s) to the issue(s) that you listed in part 2. Note that the rationale for the answers should be provided in the next section, as outlined below. 4. Technical analysis and support for your conclusions and recommendations. In this section, you should include the following, if the sources of tax law are relevant to your analysis (only some of the primary authorities listed may be applicable to your issue client situation): A. Discussion of relevant Internal Revenue Code provisions. These provisions will be more general in nature but, nonetheless, are important as they provide the basis for allowing the taxpayer to obtain the tax treatment you are recommending. The use of direct quotes is English (United States Focus 1135 words BE X1W MacBook Pro 000 da > able Window Help 97% AC371 Tax Research Memo Project 2 Fall 2020 - Compatibility Mode Saved to my Mac Draw Design Layout References Mailings Review View Tell me Share es New 12 ' ' Aav A 21 I Veb X X A LA IE Dictate Styles Styles Pane Sens the tax treatment you are recommending. The use of direct quotes is acceptable when you are listing the guidance contained in the relevant Internal Revenue Code provisions. B. Discussion of relevant Treasury Regulations, if any. The regulations will generally provide more specific guidance and examples related to the Internal Revenue Code provisions. C. Discussion of other relevant rulings, revenue procedures, notices, announcements, or other sources of administrative guidance provided by the Treasury Department and the IRS, if applicable. D. Discussion of court cases supporting your recommendation(s) to your client, if any. i. In your discussion of the cases, sparing use of direct quotes is acceptable. You must first explain the facts and decision in the court case and then explain how the findings relate to your taxpayer's situation. You should read the full text of the court case. E. Discussion of any other sources you located, including secondary authorities or other IRS publications. See Exhibit 2-5 in Chapter 2 of the textbook for a list of the proper citation formats for achtsfeta administrative and indicial authorit Vancould utilia mila Engish (United States Focus 1135 words DE 21 09XW MacBook Pro Assignment You are functioning in the role of tax advisor to the client in the assigned research project. You should prepare a memorandum which summarizes your research and conclusions related to the tax issue(s) presented by your client for consideration. The issue for consideration is outlined at the end of this document. While you may discuss the issues presented by your client and the database search process with other members of your class, each individual should prepare his/her own technical memorandum and should not receive any assistance from other class members with respect to the written analysis contained in the memorandum
