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Acct429 Week 7 Research Project 2015

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ACCT429 Week 7   Research Project 2015
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Each page must have at least a one-inch margin on all sides and be double-spaced. A separate document for each of the three portions of the assignment.•The tax memoranda in traditional tax memorandum format.Tax research memoranda use a fairly standard format and structure that is different from your typical essay assignment. The four parts include the following.
1.Facts: In this section, you summarize the facts about the transaction or events that are relevant and material to the tax questions being asked. Frame them as precisely and succinctly as possible, and write them so that they can be understood by someone who has no knowledge of the underlying facts.
2.Question Presented or Issue: This is a succinct (usually one sentence) question that you are trying to answer or resolve in the memorandum.
3.Short Answer: This is a succinct (usually one or two sentence) answer to the question presented.
4.Analysis: True to its title, this section contains all of the substantive analysis that you needed to perform to come to the short answer to the question presented. It discusses, in logical order, the various tax authorities to establish the tax rule or rules that apply to the fact pattern given. This includes such efforts as an analysis of the facts of these other cases and the language of the applicable Code section(s) at issue. Once the rules are established, it then applies those rules to the facts in the case in order to reach the conclusion that is summarized in the short answer.

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