The topic is about Taxation reporting, I already complete the first draft for the research, but I still want someone give me their advises about the case. Please read the "Case" first, and then followed the Law's requires to make the "Table". In the table, you don't need to write the Reference, but I want the citation, research, and Application(your opinions for the law) down.

Practicing Research to Writing Writing assignment 1: 1. Review the Pennsylvania Writing Assessment Domain Scoring Guide available to you in your course handouts in Canvas; noting the definition of each domain and the scaling of quality in each domain. Observe how your grading rubric ties into the PA Writing Assessment Domain Scoring Guide. Please keep in mind the standard of care expected of you as a tax professional. Every document you write should be written professionally (including tweets, text messages, emails, blogs, memos, letters, etc.). Why is that? Bottom line is you never know who will see what you write. Your boss, your future boss, your spouse, the newspaper, the courts if litigation ensues, are all examples of who might end up reading what you write, whether you intended the document for the audience or not. 2. Draft a brief, well written memorandum to your client in good format (See IRAC template) that answers this question: Can you sign the return with this tax position included or not? If you can sign the return incorporating that tax position, are there any corollary actions you should take? If you decide you can't, what should you advise your client/friend is an appropriate course of action? 3. Here your background information: You are a new manager and you brought in a $150,000 individual income tax engagement on a referral from a friend that is the tax director at a major client of your firm. Your quality reviewer seems to have some issues with deducting the charitable contribution of the development rights (qualified conservation contribution) associated with the real estate near a golf course the new client owns. Your client has valued those rights at $39,000,000 and he wants to deduct the full amount from his income in the year you are preparing the return. Due to a repurchase clause in the contribution agreement, your firm's quality reviewer says the client's tax return position has a likelihood of surviving IRS examination of a 1 in 4 chance; rising at best to a 35% chance of surviving a challenge by the IRS. The fact that this new client is contemplating running for President of the United States has further raised the reviewer's anxiety. 4. Additional guidance to consider for your memorandum: Your memorandum must be in good form (Use IRAC template as a format.) that identifies what the issues are and how you should address those issue(s) for your client: Using the facts and circumstances noted above, your memorandum should address (at a minimum) a. A recitation of your facts and circumstances and the question(s) as you have clarified them. Additionally, you must cite the relevant authorities using Bluebook citation method. You should analyze those authorities for the purpose of applying those authorities to answer your question(s), and conclude with a clear statement of what professional standards require you to Penn State Accounting 405 Tax 1, Spring 2017 do. You conclusions should also provide your client with a recommended course of action. b. Edit your memo using the \"PA Writing Assessment Domains Scoring Guide\". When you are satisfied you have \"4\" levels of writing in each domain, submit your memorandum and table of authorities to the drop box. Save your file using this nomenclature: yourlastname405ethicsmemoSP16.docx c. You must complete a table of authorities (\"TOA\") (see the template under \"Student Resources\") as a means to document and analyze the authorities you research. You are expected to document your thinking in the TOA in such a fashion that drafting your memorandum is largely a cut and paste job from your TOA. Remember how to use the TOA: i. Complete the heading information; especially the keywords you plan to use to search the BNA, CCH Intelliconnect, RIA Checkpoint Data Base or other sources. Consider keywords like \"substantial and authority\Carl P. Adams, CPA Table of Authorities Research Project Name: General Topic: Keywords: Prepared by: Reference Date prepared: Citation Research/Facts/Observation/Legal Precedent qattachments_24b06a0d222f934d958c971028ed0cdadbb25894.docx Date Checked: Application (What does it mean?) Page: 1 Checke d