Scenario

You are a tax professional with a regional CPA firm, and part of your duties include educating less experienced staff on how to conduct research. You ask two new staff members to look into whether swimming pools can be considered a medical expense for a client with osteoarthritis.

One staff member discovers and brings to you Private Letter Ruling $8208128,11/27/1981$ and says yes, a pool is a medical expense.

The other staff member discovers and brings to you Revenue Ruling $83-33$ and says yes, a pool is a medical expense.

Applying the private letter ruling and the revenue ruling to a pool as a medical expense will help you better understand the differences between these rulings.

Directions

For this memo, describe the feedback you would provide to each staff member in the scenario.

Specifically, you must address the following rubric criteria:

Private Letter Ruling: Apply the private letter ruling to a pool as a medical expense.

Private Letter Justification: Justify the use of the private letter ruling for or against a pool as a medical expense.

If the ruling does not apply to this expense, describe the steps the staff member will need to take to find the correct ruling.

Revenue Ruling: Apply the revenue ruling to a pool as a medical expense.

Revenue Ruling Justification: Justify the use of the revenue ruling for or against a pool as a medical expense.

If the ruling does not apply to this expense, describe the steps the staff member will need to take to find the correct ruling.

Facts: Explain the importance of the facts to the tax consequence.