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Tax Research Memorandum #2 Due on: 4/17/22 Max Points: 70 Dione Phillips and two friends from law school recently formed Phillips and Associates as
Tax Research Memorandum #2 Due on: 4/17/22 Max Points: 70 Dione Phillips and two friends from law school recently formed Phillips and Associates as a limited liability partnership (LLP). The income generated from the partnership will be split equally among the partners. The partnership will generate fee income primarily from personal injury cases. While some attorney friends have suggested that the partners earnings will be self-employment income, other attorneys they know from their local bar association meetings claim just the opposite. After examining relevant authority, draft a research memo following the format in Exhibit 2-9 on page 2-20 of your textbook detailing the facts, issue, authorities consulted, conclusion, and analysis. (Hint: See 1402(a)(13) and Renkemeyer, Campbell & Weaver LLP v. Commissioner, 136 T.C. 137 (2011)) Helpful Resources: 1. Use my posted document titled NexisUni Case Search.pdf to help you obtain the needed information on the cases you will research from ODU's Library website. 2. Spilker, Brian; Ayers, Ben; Barrick, John; Outslay, Ed; Robinson, John: Weaver, Connie, Worsham, Ron, Taxation of Individuals and Business Entities 2022-Refer to Exhibit 2-9 Sample Internal Research Memo on page 2-20 3. Chapter 2 Powerpoint slides and any other class notes.
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