The purpose of this is to enable you to meet the following goals:
1. Understand the role of a tax practitioner
2. Identify the tax issues involved in a scenario
3. Be able to conduct comprehensive tax research utilizing on-‐line tools in order to formulate a solution to the issues raised.
4. Be able to articulate and defend a tax position in writing.
Task: In order to successfully complete this assignment you must:
• Prepare a memorandum to the tax manager outlining the information you found in your research
• Information about writing for tax can be found at the M. Tx. Writing Website located at M. Tx. Writing Website.
Format the memo to include:
- Restatement of Facts (paraphrase)
- Identify at least three main issues based on these facts
- Provide a conclusion for each issue
- Include the analysis that led you to the conclusion for each issue. This analysis should refer to the primary authority that best addresses the issue.
- Primary authority would include items such as the Internal Revenue Code, Regulations, Court Cases, etc. These also should be paraphrased in order to highlight your understanding of the primary authority and how it relates specifically to the issue. Textbooks, websites, IRS publications, etc. are examples of editorial content, not law and therefore not primary authority.
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