Third Writing Assignmen (Due in 24 hours)

Writing Assignment #3

Judicial Sources

Try to limit your answer to Judicial Sources only in writing them Memo. Use the Tax Court Citation Manual I provided to check your citations.

Requirements: use both AI and CCH Tax Connect to explore the answers to the following fact pattern and provide an internal tax memorandum and a Client letter covering the results of your research.

1, provide copies of your prompts (we need to work on those)

2. provide copies of your AI output

3. provide revised AI output to deliver final workproduct you would be happy to provide to your boss and your client for review and consideration.

On March 15, 2020, the shareholders of Artifice Corporation (“Artifice”) met and unanimously ratified the sale of all outstanding stock of the Artifice to Unrelated Co. Immediately following the shareholder meeting, the corporation’s board of directors unanimously approved our client’s (Ron Jaworski) request to be able to transfer a portion of his shares to Wellknown Charitable Gift Fund, a tax-exempt charitable organization able to accept charitable transfers and qualify the donor for a 50% charitable deduction. Thereafter, the Artifice and the Urelated, Co., the purchaser of the shares continued drafting and revising the definitive Stock Purchase and Contribution Agreement.

On May 1, 2020, Fidelity Charitable received a stock certificate duly endorsed and approved from Mr. Jaworski (our client) and the corporation.

On June 20,2020, the Stock Purchase and Contribution Agreement was revised to specify that Jaworski contributed shares to Wellknown Charitable Gift Fund on May 20, 2020, and on May 31, 2020, the Stock Purchase and Contribution Agreement was signed buy all required parties and the transaction was funded.

Wellknown Charitable, having provided an Irrevocable Stock Power as part of the transaction, received $4,000,000 in cash proceeds from the sale, which was deposited in Our Client’s donor-advised fund giving account.

On October 31, 2020, Wellknown Charitable sent Our Client a contribution confirmation letter (which he copied to us) acknowledging a charitable contribution of the corporate shares and indicating that Wellknown Charitable received the shares on May 1, 2020.

On his 2020 tax return, our client did not report any capital gains on the shares contributed to Wellknown Charitable but claimed a noncash charitable contribution deduction. In support of the claimed deduction, a Form 8283 was attached to the return.

Our Client’s 200 tax return was selected for examination. The IRS issued a notice of deficiency to our client, determining a deficiency of over $600k, resulting from the disallowance of the claimed charitable contribution deduction, and a penalty of over $130,000 under section 6662(a).