Instructions in file attached.
Tax Research Memorandum
To: File
From: Your Name
Date: Enter Date
Re:
Client name and Tax Year.
Facts
Paraphrase the relevant facts. Remember that this is going to the client’s file and be reviewed and used by someone unfamiliar with the case.
Issue & Conclusion #1
Issue: State the most important issue in the form of a question?
Conclusion: Answer to the question above in one to two sentences.
Analysis 1
Explain here how you came to the conclusion above, relate back to the case and be sure to cite primary authority. Explain how that primary authority relates to the facts of this case. For example if you find a court case where the court findings are helpful to your argument explain how the facts in that case are similar to the facts of the client. This should be at least a paragraph or two in length for each source. At least one primary source per issue, all citations included in the memo can be either footnoted or inline. Inline citation example: “Pursuant to IRC
§123 income earned by a taxpayer which is not related to blah blah blah would be taxable.” Repeat the same process for each issue.
Issue & Conclusion #2
Issue:
Conclusion:
Analysis 2
Issue & Conclusion #3
Issue:
Conclusion:
Analysis 3
Issue & Conclusion #4
Issue:
Conclusion:
Analysis 4
Issue & Conclusion #5
Issue:
Conclusion:
Analysis 5
