I have attache the document…. Performing tax research to find correct answers to a given tax situation and composing memoranda summarizing these findings are important parts of tax practice. 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 authorities—such as the applicable Code sections and court opinions—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. 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. This portion of the Project is worth 20 point.