TO: Hy Incmm Tax Partner in Charge

FROM: Ima Pyoopul Assistant Tax Specialist (customize for you before submitting)

DATE: March 24, 2016

SUBJECT: Research Project Case Number YY (note please remove the shading below before submitting your memo)

FACTS:

In this section of the memorandum a student should essentially copy the facts (text) of the case problem you have selected from the posted list (to the extent your case specifies a general question(s), do not include that language here but below in the Queries section). You must not make any material modifications or embellishments to the facts of the problem as provided.

QUERIES:

In this section of the memorandum a student would delineate in sufficient detail the tax question or questions identified in the case facts. This section pertains to Phase 1 of the project and is your first significant challenge to identify what the major tax issue or issues is/are in your case. While your case may already contain a general question or statement, a student generally must augment and/or restate the question(s) in greater detail. Note the due date of Phase 1 as specified in the course syllabus students must submit the tax issue(s)/query(ies) they have identified via the BlackBoard Message Function - see Appendix A to the course syllabus for more information.

CONCLUSIONS:

This section of the memorandum sets forth, in concise summary form, the conclusions derived from the arguments and authorities set out below. There should not be any intuitive leaps all conclusions should flow from the cited research.

ARGUMENTS AND AUTHORITIES:

This section of the memorandum contains a students technical analysis of the issue(s) at hand along with appropriate supporting citations (proper citation format is important). This analysis should include all pertinent and relevant primary sources (e.g. IRC, Revenue Rulings, Treasury Regulations, court cases, etc.) as well as any secondary sources used to support the analysis (e.g. CCH explanation). Emphasis must be placed on primary sources do not simply cut and paste a CCH explanation or IRS Publication and call it a day. Students should generally list at least three (3) primary sources in completing this project. For example, a student might include the relevant IRC section, a related Treasury Regulation and a Revenue Ruling or Court Case addressing their issue. Please review the sample research memorandums posted to BlackBoard for more information as to what this section should contain.