Tax Research Memorandum


Juan is a very successful lawyer and a good son. He pays $6,000 a year toward the support of his mother Ana, aged 69, a U.S. citizen and resident. She earns $3,000 and spends all of it for her own support. She lives in the same home Juan grew up in which has no mortgage. In addition, Medicare pays $4,500 of her medical expenses. Ana does not receive any other financial support. Juan is single.

Juan has heard that you are a tax wizard and wants you to be his tax advisor. In preparation for that meeting you will use the tax research services to investigate the issues. Using primary authority only, as your sources, write a memo (2-5 pages) to the file detailing the various issues you plan to discuss with Juan.

  • Prepare a memorandum to the tax file, (2-5 pages) double spaced outlining the information you found in your research.
  • Information about writing for tax can be found at the M. Tx. Writing Website located at M. Tx. Writing Website. Format the memo to include:

o Restatement of Facts (paraphrase)
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 in order to highlight your understanding of the primary authority and how it relates specifically to the issue. Textbooks, websites, IRS publications, etc. are examples of editorial content, not law and therefore not primary authority.

o See example memo for proper formatting.

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