Prepare a memorandum to the tax manager outlining the information you found in your research.
Follow the examples of file memoranda using the formatted Word document included. Format the memo to include:
o Restatement of Facts
o Identify at least three main issues based on these facts.
o Provide a conclusion for each issue
o 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.
o Primary authority would include items such as the Internal Revenue Code, Regulations, Court Cases, etc. These also should be paraphrased to highlight your understanding of the primary authority and how it relates specifically to the issue. IRS Publications and Tax Topics are NOT considered primary authority for this assignment.
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