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Question 4 - Tax Research (66 points) - Identification of issue(s) 8 points) - Locating, analyzing, and properly citing authority (25 points) - Arriving at
Question 4 - Tax Research (66 points) - Identification of issue(s) 8 points) - Locating, analyzing, and properly citing authority (25 points) - Arriving at proper conclusion(s) (20 points) - Tax Memo - proper format for memo written with proper grammar, spelling etc. (13) points) Diana Dodger has not paid taxes in years, despite having a successful small business and investment income. The IRS finally caught up with her and issued an assessment of $225,000 for back taxes, interest and penalties. Diana is adamant that she will not pay the amount because the levying of taxes by the federal government is "unconstitutional". Furthermore, she asserts that she is a citizen of Washington (a state with no personal income tax) where she resides and not a "federal citizen", thus exempting her from any federal taxes that may exist. She wants to petition the Tax Court using these arguments to reverse the IRS assessment. Assume that the calculation of the assessment, penalties and interest is substantially correct. What advice do you have for Diana about pursuing her case with the Tax Court? Your advice should address the merits of her position and explanations of the likely financial outcome of her arguments with the Tax Court. Your memo should address and cite relevant code section(s) and recent Tax Court Memorandum decision(s) that you deem applicable to her situation
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