The key to becoming a well-respected leader in the tax field, or any business/accounting/finance field is to be able to accurately and efficiently communicate technical concepts, issues, and proposed resolutions using layman's terms Facts The Facts section should ONLY include facts required for the reader to make an informed decision about the accuracy of your research conclusions. You should not include any facts that are inconsequential. When the facts include numerical details such as multiple dates or amounts, you should consider using a bulleted format or table layout to enhance comprehension of the details. Issue The issues section is where you will list the questions your client has asked you to address. When there is more than one issue to resolve, using a numbering format is an effective way to organize the memo. Avoid creating issues that aren't relevant to the matter at hand; but on the other hand, you should be all-inclusive with your issue identification. Conclusion The Conclusion section is where you will provide the solutions to the client's issues. If you used a numbered format in the issues section, you should follow the same format. Do not provide conclusions for any issues not identified in the issues section. You should INCLUDE the solution but EXCLUDE the reason for the solution. Example: if the solution to an issue is 4 and the computation was 8 + 12-7+32-414, you would state "The answer is 4" in the Conclusion section. The computation belongs in the Analysis section. Analysis The Analysis section is where you will defend your conclusion(s). You should analyze each issue separately, if you used a numbered format in the issues section, you should follow the same format. Your analysis of each issue should begin with relevant internal Revenue Code statutory/regulatory cites. If you require further support for your conclusion, you may then refer to "weaker" defenses (i.e. revenue rulings/procedures, court cases, IRS web site references, etc.) It is extremely important to SUMMARIZE the authoritative guidance information for the client using "PLAIN LANGUAGE" and EXPLAIN how the guidance applies to the client's issue in YOUR OWN WORDS Other Advice for Professional Tax Memos Throughout the memo, be as succinct as possible. The tax rules and regulations are difficult enough to analyze as it is, there is no need to include "fluffy language; there is no need to include inapplicable authoritative guidance; there is no need to create issues that the client isn't interested in resolving now