Performing tax research to find correct answers to a given tax situation and composing memoranda summarizing these findings are important parts of tax practice. As there are a number of authoritative primary tax law sources. The first, the Internal Revenue Code, is the law enacted by Congress. The Treasury Department and the Internal Revenue Service publish a number of materials that interpret and provide decisions, pronouncing their interpretation and application of the Code, including Treasury regulations, revenue rulings, and revenue procedures. Finally, courts are often asked to hear tax disputes between taxpayers and the United States, and these courts issue rulings that interpret and apply the tax law, creating additional tax authority in the process. These combined writings constitute primary tax law authority, and these are the authorities that tax practitioners rely upon when a client asks for their opinions regarding how a proposed or a completed transaction should be treated for tax purposes.
In this project, you will be presented with two such transactions and asked to answer one or more tax questions related to these transactions. You will be provided with selected primary authoritiesâ€”such as the applicable Code sections and court opinionsâ€”that are relevant to these transactions and questions. Accordingly, you will need to read and analyze these authorities, apply their holdings to the facts you are given, and conclude how the transaction you are given should be treated for tax purposes. You will then document all of these findings and conclusions in a tax file memorandum, as explained and outlined in Chapter 2 of your text. Each of these two memoranda is worth 30 points, for a combined total of 60 points.
In addition to these two transactions, you will be presented with a third research project that will introduce a particular tax concept or current issue of tax law and ask you to perform some research and analysis related to that concept or issue. To complete the project, you will be required to perform Internet research to find materials relevant to these concepts or issues, as well as complete a written analysis and explanation of these materials and findings that answers one or more questions posed by the problem.
The Research Essay should be completed using a conventional essay format. A thorough submission should consider including all of the following elements:
- Cover Page: Include who you prepared the paper for, who prepared it, and the date.
- Table of Contents: List the main ideas and section of your paper and the pages in which they are located. The illustrations should be included separately.
- Introduction: Use a header on your paper. This will indicate that you are introducing your paper. As you know, the purpose of an introduction is threefold:
- to introduce the subject and why the subject is important;
- to preview the main ideas and the order in which they will be covered; and
- to establish a tone of the document.
Include in the introduction a reason for the audience to read the paper. Also include an overview of what you are going to cover in your paper, and the importance of the material. (This should include or introduce the questions you are asked to answer on each assignment.)
- Body of Your Report: Use a header titled with the name of your project. Example: “The Development of Hotel Xâ€”A World Class Resort.” Then proceed to break out the main ideas. State the main ideas, state major points in each idea, and provide evidence. Break out each main idea you will use in the body of your paper. Show some type of division like separate sections that are labeled; separate groups of paragraphs; or headers. Include the information you found during your research and investigation.
- Summary and Conclusion: Summarizing is similar to paraphrasing but presents the gist of the material in fewer words than the original. An effective summary identifies the main ideas and major support points from the body of your report. Minor details are left out. Summarize the benefits of the ideas and how they affect the subject.
Works Cited: Use the citation format… APA format is needed