ACCT429
Week 7 Research Project 2015
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Each page must have at least a one-inch margin
on all sides and be double-spaced. A separate document for each of the three
portions of the assignment.•The tax memoranda in traditional tax memorandum
format.Tax research memoranda use a fairly standard format and structure that
is different from your typical essay assignment. The four parts include the
following.
1.Facts:
In this section, you summarize the facts about the transaction or events that
are relevant and material to the tax questions being asked. Frame them as
precisely and succinctly as possible, and write them so that they can be
understood by someone who has no knowledge of the underlying facts.
2.Question
Presented or Issue: This is a succinct (usually one sentence) question that you
are trying to answer or resolve in the memorandum.
3.Short
Answer: This is a succinct (usually one or two sentence) answer to the question
presented.
4.Analysis:
True to its title, this section contains all of the substantive analysis that
you needed to perform to come to the short answer to the question presented. It
discusses, in logical order, the various tax authorities to establish the tax
rule or rules that apply to the fact pattern given. This includes such efforts
as an analysis of the facts of these other cases and the language of the
applicable Code section(s) at issue. Once the rules are established, it then
applies those rules to the facts in the case in order to reach the conclusion
that is summarized in the short answer.
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