• Attached are files that contain a template of a research memo, an example of a research memo, tax research guidance, list of primary source authority, and the actual case that you need to do the memo for (it also contains how the memo will be graded). More examples can be found at the M. Tx. Writing Website.
• Prepare a tax research memorandum outlining the information you found in your research.
• Format the memo to include:
o Restatement of Facts (paraphrase)
o Identify at least five main issues based on these facts
o Provide a conclusion for each issue
o 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.
o 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. Tax Topics and IRS publications are NOT primary source material.
On the sources section in the order, I selected 5 since there are 5 main issues that need to be identified.
I currently purchased 6 pages; however, if you need more pages to fully answer the questions I can add more pages. Thank you!
