Write a memo for your tax files that explains the facts, analysis, and conclusions based on your tax research on CCH Tax Research Network / Intelli connect. You need to rely on (and cite) at least one primary source of law (e.g., Internal Revenue Code or Treasury Regulation).

Scenario:

1. Your client, Mr. Torero, fell down a flight of stairs and broke his back. His doctor prescribed physical therapy in a pool to treat Mr. Torero’s ailments. In response to this advice (and for no other reason), Mr. Torero built a swimming pool in his backyard and strictly limited use of the pool to physical therapy. Mr. Torero paid $25,000 to build the pool, but he wondered if this amount could be deducted as a medical expense. Determine if a capital expenditure such as the cost of a swimming pool qualifies for the medical expense (itemized) deduction.

USE THE FOLLOWING FORMAT:

(See Exhibit 2-9, Sample Internal Research Memo, on page 2-20 of the textbook, for more detail)

MEMO #: ____

NAME: ________________________

FACTS: Briefly describe the facts behind the tax issue.

ISSUE: What is the tax issue you are trying to answer?

AUTHORITIES: [List at least one primary source of law on which this memorandum is based, e.g., IRC Sections, Treasury Regulation Sections, Revenue Ruling, etc.]

CONCLUSION: Briefly state your conclusion.

ANALYSIS: The analysis should start with a description of the general area(s) of tax law that applies to the issue (e.g., IRC Section), followed by a discussion of specific authorities (e.g., Regulation Sections, Revenue Ruling, etc.). Next explain how the law applies to the tax issue. Complete your analysis with a brief conclusion.

Writing 'Basics' to Keep in Mind:

1. The memo should be one- to two-pages in length.
2. Double-space the text.
3. Indent the paragraphs.
4. Use one-inch margins.
5. Use topic sentences.
6. Paragraphs must have at least three sentences.
7. Keep sentences short. If a sentence goes over two lines, check to see if you can use two sentences in place of one. Resist wordiness.
8. Use the ‘Spelling and Grammar’ tool available on Microsoft Word! Note that a spelling error occurs even if the word is spelled correctly, but the word usage is incorrect (e.g. there instead of their).
9. Do not use contractions.
10. Focus on subject/verb agreement when using terms such as 'Congress', 'Internal Revenue Service', and 'Treasury Department'. (These terms are singular, not plural!)
11. Write ‘12 percent’ instead of ‘12%’ or ‘twelve %’.

Limit usage of the passive voice.