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Use the attached file to find the case you have been assigned (Hawaiian Case)
The second attached file (Tax Memo – Template) can be used as an example of the proper format for the preparation of a tax research memo:
Task: In order to successfully complete this assignment you must:
Prepare a memorandum to the tax manager outlining the information you found in your research.
Format the memo to include:
Restatement of Facts (paraphrase)
Identify at least three main issues based on these facts
Provide a conclusion for each issue
Include the analysis that led you to the conclusion for each issue. This analysis should refer to the primary authority that best addresses the issue.
Primary authority would include items such as the Internal Revenue Code, Regulations, Court Cases, etc. These also should be paraphrased in order to highlight your understanding of the primary authority and how it relates specifically to the issue. Tax Topics and IRS publications are NOT primary source material.