Detailed Tax Assessment and Solutions for [Client Name], [Tax Year]

Tax Research Memorandum

To: File

From: Your Name

Date: Enter Date

Re: Client name and Tax Year.

Facts

Paraphrase the relevant facts. Remember that this is going to the client’s file and be reviewed and used by someone unfamiliar with the case.

Issue & Conclusion #1

Issue: State the most important issue in the form of a question?

Conclusion: Answer to the question above in one to two sentences.

Analysis 1

Explain here how you came to the conclusion above, relate back to the case and be sure to cite primary authority. Explain how that primary authority relates to the facts of this case. For example if you find a court case where the court findings are helpful to your argument explain how the facts in that case are similar to the facts of the client. This should be at least a paragraph or two in length for each source. At least one primary source per issue, all citations included in the memo can be either footnoted or inline. Inline citation example: “Pursuant to IRC §123 income earned by a taxpayer which is not related to blah blah blah would be taxable.” Repeat the same process for each issue.

Issue & Conclusion #2

Issue:

Conclusion:

Analysis 2

Issue & Conclusion #3

Issue:

Conclusion:

Analysis 3

Issue & Conclusion #4

Issue:

Conclusion:

Analysis 4

Issue & Conclusion #5

Issue:

Conclusion:

Analysis 5

Citation to Primary Authority PRIMARY AUTHORITY CITATION Committee Report House Committee on Ways and Means, H.Rep. No 432, 98th Cong., 2d Sess. (March 5, 1984). Internal Revenue Code Sec. 469 (e)(1)(A). Treasury Regulation – final Reg. Sec. 1.269-1(a)(3). Treasury Regulation – proposed Prop. Reg. Sec. 1.704-3(c). Treasury Regulation – temporary Temp. Reg. Sec. 1.441-1T(a)(2). Revenue Ruling – temporary cite Rev. Rul. 84-101, 1984-28 I.R.B. 5. Revenue Ruling – permanent cite Rev. Rul. 54-56, 1954-2 C.B. 108. Revenue Procedure – temporary cite Rev. Proc. 93-15, 1993-3 I.R.B. 12. Revenue Procedure – Permanent cite Rev. Proc. 88-12, 1988-1 C.B. 17. Announcement – Temporary cite Ann. 2011-77, 2001-30 I.R.B. 83. Announcement – Permanent cite Ann. 2001-77, 2001-2 C.B. 83. Notice – Temporary citation Notice 2002-64, 2002-41 I.R.B. 690. Notice – Permanent citation Notice 2002-64, 2002-2 C.B. 690. Private Letter Ruling LTR 8450056 (PLR) or LTR 200343030 (PLR) U.S. Tax Court- regular decision J.B. Linderman, 60 T.C. 609 (1973) U.S. Tax Court – memorandum decision Thomas E. Lesslie, 36 TCM 495 (1977), T.C. Memo ¶77,111. Acquiescence Phillip G. Larson, 66 T.C. 159 (1976), acq. 1979-1 C.B. 1. U.S. District Court Arnold v. U.S., 289 F. Supp. 206, 68-2 USTC ¶9590, 22 A.F.T.R.2d 5661 (E.D. N.Y., 1968) U.S. Court of Federal Claims Zuchman v. U.S., 524 F.2d 729, 75-2 USTC ¶ 9778, 36 A.F.T.R.2d 75-6193 (Cl. Ct., 1975) U.S. Court of Appeals Comm. V. Percy W. Phillips, 275 F. 2d 33, 60-1 USTC ¶9294, 5 A.F.T.R.2d 855 (4th Cir., 1960). U.S. Supreme Court Commissioner v. Duberstein, 363 U.S. 278, 80 S. St. 1190, 60-2 USTC ¶9515, 5 A.F.T.R.2d 1626

(1960)

Temporary cite – Refers to Internal Revenue Bulletins which are published weekly. Permanent cite – Refers to Cumulative Bulletin (C.B.) which is printed semiannually and includes IRS pronouncements, previously included in a weekly bulletin. Citations should be to the C.B. unless it is not contained in the most recent C.B. Acquiescence – Whenever the IRS indicates that it will accept the decision of the court, it should be included in the citation by adding acq. followed by the citation to the bulletin where the acquiescence can be found. If the IRS indicates that it will not accept the ruling by nonacquiescence this is also cited as nonacq. followed by reference to bulletin.