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Tax Memorandum: To: File From: Your Name Date: Enter Date Re:Client Name and Tax Year

This tax memorandum concerns Client Name and Tax Year. It addresses five key issues relating to the client's tax situation. For the first issue, the memorandum concludes that the client's income from X activity would be taxable based on IRC §123 and a related court case with similar facts. The second issue concludes that the client qualifies for a deduction under §456. The third issue finds that penalty Y does not apply based on ruling Z. The fourth issue determines that loss A can be carried forward based on §789. The fifth issue concludes that expense B is not deductible as per §987.

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127 views3 pages

Tax Memorandum: To: File From: Your Name Date: Enter Date Re:Client Name and Tax Year

This tax memorandum concerns Client Name and Tax Year. It addresses five key issues relating to the client's tax situation. For the first issue, the memorandum concludes that the client's income from X activity would be taxable based on IRC §123 and a related court case with similar facts. The second issue concludes that the client qualifies for a deduction under §456. The third issue finds that penalty Y does not apply based on ruling Z. The fourth issue determines that loss A can be carried forward based on §789. The fifth issue concludes that expense B is not deductible as per §987.

Uploaded by

DW
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOC, PDF, TXT or read online on Scribd

Tax 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 inline. Inline citation example: “Pursuant to IRC §123 income earned

by a taxpayer which is not related to blah blahblah 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

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