REVISE ACCOUNTING PAPER

RESEARCH PROJECT

A single pdf or Word document of the submitted project is strongly preferred.

Format

Your answer should be no more than 2-3 pages (approximately 250 words per page) typed in a word processing program. The answer should be structured in memorandum form as follows.

There are similar examples in Chapter 2 in the South-Western Federal Taxation Comprehensive Volume and in Chapter 2 in the South-Western Federal Taxation Taxation of Business Entities Volume and South-Western Federal Taxation Essentials of Taxation Volume.

In addition, I have a sample completed Taxation Project with the file name 997ResMemoHusbandF13draft52114factsformatedit2314 (Please be aware that the particular sample may have lent itself more to quotations of the law. Often, law quotations need to be paraphrased by the drafter of a memorandum.)

TO: File of (taxpayer name). (Your audience is other CPAs in your firm as peer review.)

FROM: (your name)

RE: (state issue) (issue is stated in the separate Tax Research Problem posted in blackboard)

DUE: (due date)

CONCLUSION: (short statement)

REASONING: (body) (generally in your own words; some quotes may be appropriate)

state the facts of the taxpayer in the assigned problem

state the rules of law from, e.g., case(s), and/or IRS rulings and pronouncements, and/or the Code, and/or Regulations, etc.

show your reasoning (apply the law to the facts of the taxpayer in the assigned problem)

conclusion repeated

Attach 1-2 pages from CCH (plus the “History”) and 1-2 pages from Westlaw (plus the “History”) to show that you were able to locate appropriate primary authority. Usually, the professor provides some guidance in the specific Tax Research Problem posted in blackboard as to what item of authority (e.g., a case or Revenue Ruling) may be the most appropriate. The closer any facts in the authority, which you locate, are to the facts in the Tax Research Problem, the more appropriate that authority is for resolving the issue of the Tax Research Problem.

Suggested Research Sources and Citation Format

CCH Standard Federal Income Tax Reporter and Westlaw are available on-line through the Pfau library website. (These sources should be sufficient.)

The San Bernardino Law Library (885-3020) and the Riverside Law Library, 3989 Lemon (275-6390), have been open to the public in the past. Please call for hours if the library is used. If the law libraries are used, the sources most likely to be useful are BNA’s Tax Management Portfolios (Income Tax) and possibly RIA.

Citations should be in the format the texts use in their footnotes as, for example, in Chapter 2. The texts’ citations would be acceptable in practice and are loosely based on the most appropriate book on the form for legal citations, A Uniform System of Citation. For the format in that book, see also websites such as http://www.law.cornell.edu/citation/ or http://www.scu.edu/lawreview/bluebook.htm and see http://www.americanbar.org/content/dam/aba/publishing/tax_lawyer/ttlstyle.authcheckdam.pdf

In a memorandum, citations usually appear in the text preceding or following statements which the citations support, either as a part of the sentence or as a separate citation sentence, if the citation follows a statement. Citations are in footnotes in a research piece such as a law review article or in a textbook. Please do not surround citations with [brackets] as in the textbooks’ examples.