Some students have trouble implementing the FILAC memo structure, so let me describe it again. It is quite logical. The FACTS section summarizes all relevant facts in one place. No relevant facts should appear for the first time later in the memo! The ISSUES section describes the tax issues you research and document in the memo. Do not present issues for the first time in any other section. The LAW section discusses the tax rules that your research uncovered. In this section you will summarize the rulesyou need to talk about the rules in your own words; do not merely copy and paste from AnswerConnect! This tells the reader that you understand the rules you researched. You should at least read the appropriate code sections and scan their related regulations. Also, do not talk about the facts of the case in this section. This is the purpose of the ANALYSIS section. In this section you will apply the rules you summarized in the law section to the facts of the case to address the issues you identified in the issues section. Finally, the CONCLUSION section states all your conclusions all in one place. This is not the section for deriving your conclusions; your memo should do that in the analysis section. For example, if your solution involves a calculation, do that in the analysis section and not in the conclusion section. One more thinggiven that you are relatively new to tax research, do not deviate from this structure. Practitioners sometimes deviate from it, but many do not, and none of the research problems below are complex enough to warrant a more elaborate structure.

Here are examples of properly formatted citations to primary authority:

Source	Example Citation	Comment(s)
(IRC) Internal Revenue Code	162(m)	Here, 162 is the section number and the (m) is the subsection. There are other divisions as well. Write out Section if at the start of a sentence.
Treasury Regulations	Reg. 1.162-3(a)	This is the third regulation that relates to IRC 162. The (a) is a sub-part of the regulation.
Revenue Ruling	Rev. Rul. 2008-16	This is the 16th revenue ruling written by the IRS in 2008. A reference to its location follows, but you can omit that.
Revenue Procedure	Rev. Proc. 92-7	This is the seventh revenue procedure written by the IRS in 1992. A reference to its location follows, but you can omit that.
Court Cases	Stock, T., 175 T.C. 201 (2012)	This is a 2012 US Tax Court case where T. Stock is the taxpayer. The case resides in volume 175 of the US Tax Court Reporter on page 201. (There are several other courts that hear tax cases.)

Required -- Please read carefully

Problem #1:

By 2023, Lucy had decided that her 12-year-old Honda Accord no longer was suitable for her business travel, particularly when it involved visits to potential customers. However, she is in a "cash bind" personally due to her investment in JL Corporation. She has come to you because she wants JL Corporation to purchase a $60,000 SUV for Jason's and her business use. She will retain her Camry for daily commuting and personal driving but use the new SUV only for JL-related travel. Lucy wants to know what the tax consequences will be for JL Corporation, including the depreciation each year if she purchases the vehicle the first of 2023. Jason and Lucy expect this vehicle to be the only depreciable asset that JL Corporation will purchase in 2023. Your senior, Jill, also wants you to compute the present value of the cost of the vehicle using a 7% discount rate after considering the tax savings from the correct depreciation schedule. JL will not use 179 or bonus depreciation for this asset even if the tax law permits it.