3-4 pages tax memo, must use check point
Document Preview:

Instructions: 1. Cases will be randomly assigned in class. 2. Research the problem using the online Checkpoint tax research database. 3. Prepare the memorandum following the format of the sample memorandum posted on Blackboard. 4. The memorandum should contain sections. a. Facts . b. Issues c. Conclusion 1. 1 6 sentences. 2. Remember, there is no right or wrong answer. Many of the fact situations may be argued either for or against the taxpayer. d. Discussion Applicable Law 1. Cite Internal Revenue Code sections. 2. Other cites could include Regulations, Revenue Rulings, and court cases. a. Use the PROPER citation forms as shown in Chapter 2. 3. a. Your particular fact situation may or may NOT have applicable Regulations, Revenue Rulings, or court cases. 4. DO try to find all applicable law regarding your fact situation. Analysis 5. In this subsection compare your fact situation to ALL the authorities cited in the “Applicable Law” subsection of this Discussion . 6. IMPORTANT !!! For EVERY authority mentioned in the “Applicable Law” subsection include a COMPLETE analysis of how EACH cited authority relates to the facts of the research problem. 7. Be SPECIFIC and THOROUGH in your comparison. Cite every authority by NAME. COMMON ERRORS ON MEMORANDUM ASSIGNMENTS WHICH WILL RESULT IN POINT DEDUCTIONS 1. Failure to begin “Applicable Law” subsection with cite to a Code section. ALWAYS start with a code section, not the related Regulation. 2. Failure to give a full citation to a Revenue Ruling and, less commonly, a court case. Citation forms are shown in Chapter 2 of the text. 3. Citing to the CCH, RIA, or other tax service. DO NOT cite to these services. Cite to the primary source (i.e., Code, Regulations, Revenue Rulings, etc.). A tax service cannot be cited as an authority when representing your client before the IRS or in court. 4. A weak “Analysis” subsection. Most students do a reasonable job on the “Applicable Law” subsection, but then lose steam when comparing the…


"Is this question part of your assignment? We Can Help!"