Tax Research Memo

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tax_cases_409.docx

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· Instructor:

1. One page of research the problem at any library with tax research facilities, or use online tax research database.

2. The memo should contains of four sections and Follow this format “VERY IMPORTANT”

a. Issue

a. 1-2 sentences showing the issue

b. Applicable Law:

a. Cite at least ONE applicable Internal Revenue Code section.

b. Other cites should include Regulation, Revenue Rulings, and court cases

c. Analysis

1. In this section compare your fact situation to ALL the authorities cited in the “Applicable Law” section.

2. IMPORTANT, for every authority mentioned in the “Applicable Law” section include a complete discussion of how each cited authority relates to the facts of the research problem.

3. Be specific and thorough in your comparison. Cite every authority by name.

d. Conclusion

1. 1-2 sentences

2. You don’t need to be clear in your opinion about the case but kind review the facts.

· Some Hints:

1. Applicable Law section and Analysis section should have the same number of authorities.

2. Use the Memo of the whole case in this link.

http://www.ustaxcourt.gov/InOpHistoric/graves.TCM.WPD.pdf