Prepare a memorandum to the tax manager outlining the information you found in your research.  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

Your submission should not be more than 6 pages long. 
Use the attached file to find the case you have been assigned.
Purpose:  The purpose of this is to enable you to meet the following goals:

Understand the role of a tax practitioner
Identify the tax issues involved in a scenario
Be able to conduct comprehensive tax research utilizing on-line tools in order to formulate a solution to the issues raised.
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.
 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. Tax Topics and IRS publications are NOT primary source material. 

See attached the case, but also find attached citations of primary authority and a Tax Memo Template as an example.