You must complete both fact patterns in the assignment. Also, you must use the Tax Research Memo template for the assignment. If you do not use the template, the assignment will be rejected. Don’t worry about filling out the boxes at the bottom of the template. You would do that if you were preparing this memo for a tax partner or client. All citations must be from primary and/or secondary source materials!! if you quote be sure to provide appropriate reference to the quote. In completing any IRS forms, you may quote IRS Form Instructions but must consider primary source materials in making your case on the form(s). You may quote freely but make sure you properly reference your quote(s) and/or references. If you merely cut and paste from an article, the assignment will be rejected, and the student or group will have to redo the assignment with a grade penalty.
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