The research memo should be prepared using the following four sections. Fulfilling the requirements of the four sections will result in 50 points. Note that following the descriptions of the four sections is a list of items that relate to the points for that section. It is required that you use this four section format. 1. Facts (5) a. Facts are stated clearly. b. Facts focus on necessary (relevant) items. 2. Issue (10) a. The proper issue(s) is(are) addressed. b. The issue(s) is(are) worded as a question. c. If more than one issue is present, each is listed and numbered separately in this section. 3. Conclusion (10) a. The conclusion is correct based on current law. b. The student's conclusion is logical based on the law located, even if not correct based on the entire body of law. c. Should be a one sentence conclusion for the (each) issue. d. If more than one issue was listed, there should be a corresponding, numbered conclusion for each issue. e. Authorities should not be listed in this section. 4. Authority / Reasoning (25) a. The student located the proper authority. b. The authority is presented in order of the relative weight of the authority. c. The authority is properly cited. d. The authorities are discussed, not simply copied verbatim. e. The authorities are related to the facts of the case. f. If authorities conflict, this is discussed. g. There is a summary/conclusion discussion of this section as the last paragraph. Specific potential writing problems that will cause loss of points: 1. Words are misspelled. ( 5 points each occurrence) 2. Subject and verbs do not agree. ( 5 points each occurrence) 3. Incorrect word is used in such a way as to make it elear that the student used spell check but did not proofread. (Example: the student uses the word 'if when intending to use the word 'is') ( 5 points each occurrence) 4. The use of an incomplete sentence. ( 5 points each occurrence) 5. Any one sentence paragraphs (other than the issue and conclusion statements). (5 points each occurrence) Last year, Mr: Smith was involved in an automobile accident, severely injuring his legs. As part of a long-term rehabilitation process, his physician prescribes a daily routine of swimming. Because there is no readily available public facility nearby, Smith investigates the possibility of either building a pool in his own back yard or purchasing another home with a pool. In the current year he finds a new home with a pool and purchases it for $175,000. He then obtains some estimates and finds that it would cost approximately $20,000 to replace the pool in the home he has just purchased. He-also obtains some real estate appraisals, which indicate that the existing pool increases the value of the home by only $8,000 During the current year, Smith also expends $500 in maintaining the pool and $1,800 in other medical expenses. What is the total amount of medical expenses he may claim in the current year? Smith's AGI for the year is $60,000. - Sec. 213 - Reg. Sec. 1.213-1(e)(1)(iii) - Richard A. Polacsek, 1981 PH T.C. Memo I81,569, 42 TCM 1289 - Paul A. Lerew, 1982 PH T.C. Memo I182,483, 44 TCM 918 - Jacob H. Robbins, 1982 PH T.C. Memo \$82,565, 44 TCM 1254