Question Details

ACCT 420 Week 8 Assignment 8-4: Tax Memo 3
 
Overview
The preparation of an effective and efficient tax research memorandum, requires a thorough analysis of the issue, facts, and authoritative rule, statement, or regulation to determine an appropriate conclusion, just as with a traditional research paper. During your time at Franklin, you have undoubtably become very familiar with the "IRAC" method or format for research papers consisting of four general parts:
1.	Issue(s)
2.	Rule(s)
3.	Analysis
4.	Conclusion
Utilizing this type of structured analysis helps you to focus on your writing, resulting in a more effective and well-reasoned paper.
You will be using a slightly modified version of the IRAC model or structure in completing this assignment. While the type of structured, rules-based analysis you will be doing is the same, it will be structured in a format more traditionally used by accountants and other professionals.

Action Items
1.	Complete the following research problem in your textbook, South-Western Federal Taxation:
a.	Chapter 20, Research Problem #2 on page 20-29
2.	Complete preparation of tax memo for tax research problem assigned by your professor in Week 9.
3.	Structure your memo as follows:
Your professor will review this process in more detail during class, including how to access and utilize online tax databases and services to perform the necessary tax research. Please prepare for this discussion by completing 8-4: Tax Memo 3 prior to class.
a.	Facts: Succinctly state the facts relevant to the resolution of the taxpayer's issue. Doing so involves reviewing the facts to include only those relevant to answering the question(s) at issue in your memorandum.
b.	Question Presented: State the question or questions your memorandum seeks to answer. If possible, present it in a single sentence (e.g., "Will Mr. Smith have to include the value of the property in income?"). Most (if not all) of the memoranda you will be assigned will present a single, overarching question. Granted, there may be multiple issues that you have to analyze to answer this question, but all of them go toward answering the larger question --such as whether the taxpayer has to include the value of some property in income.
c.	Short Answer: State the answer to the "Question(s) Presented" as clearly and succinctly as possible --again, preferably in a single sentence. (For example, your "Short Answer" to the "Question Presented" answer above might be, "Mr. Smith will have to include the value of the property in income.")
d.	Analysis: This is the substantive portion of your memorandum and is worth the majority of the points on the assignment. It is where you present all of the analysis that is required to support your "Short Answer." In performing your analysis, you should use the general "IRAC" approach you have learned and utilized to date, although you will not have specific sections within the "Analysis" listed as "Issue," "Rule," "Analysis," and "Conclusion." Once you have identified the issue or issues that you have to resolve to answer the "Short Answer," you will need to perform tax research to identify tax authorities to establish the controlling "rule" that resolves that issues. Your analysis for each of these issues should review these authorities and then apply them to the facts of the case to draw conclusions.
4.	Compose a 3-4 page length, double-spaced, 12 font memo showing proper tax law citation and references. Note: Please remember that this memo must be in your own words except for properly cited rules or quotes. (Please refer to Chapter 2 for proper tax law citation). Please note that you may NOT use your textbook as one of the research sources for your paper.
5.	Submit your memo to Turnitin.com and make any necessary changes to the memo as a result of this submission.
Note: When you are preparing your tax research memo, use each of the categories listed above as headings in your memo. This organization helps you steer the reader through your thought process in a logical progression. This format also ensures that you have completed the tax research process to formulate a supported, correct conclusion to your taxpayer's issue.

Submission Instructions
•	Send your completed draft assignment to Turnitin.com. Revise your assignment based on the report you received.
•	Click the Submit button in the Toolbox to upload your revised assignment by Sunday of Week 13.

Grading Criteria
•	Question and Answer Identification - Properly identifies the "Question(s) Presented" and the "Short Answer": 0 - 10 points
•	Identification of Correct Tax Authority - Identifies and states accurately the tax authority (Code sections, Regulations, Revenue Rulings, court cases, and other primary authorities) relevant to answering the "Question(s) Presented": 0 - 15 points
•	Analysis - Provides an in-depth analysis that interprets the relevant tax authority to establish the rule or rules necessary to answer the "Question(s) Presented" and then applies the rule or rules to the facts of the case to support the "Short Answer": 0 - 30 points
•	Presentation - Utilizes proper format and layout: 0 - 7 points
•	Tax Law citation - Demonstrates proper tax law citation : 0 - 5 points
•	Grammar/Spelling - Reflects correct grammatical use and spelling: