Which of the following is CORRECT with respect to a file memo?

Question $4$ options:

a$)$

It should include only the strengths of the client's position.

b$)$

It should include a list of the tax issues that are in dispute and a matching conclusion for each identified issue.

c$)$

It should be prepared only in closed$-$fact situations.

d$)$

All of these are correct.