Help me with my Tax Memo

I need help with my Tax memo for my Taxation class. The details consist of:

-Prepare a tax research memo addressing the question that has been raised.Please note that if the tax memo is
not in the required format and/or contains very little analysis you will receive a zero (0) for the assignment. All
good faith efforts are capable of receiving a minimum of 60% but less than a good faith effort will be awarded zero
points.

You will need to support your conclusion using primary sources of tax law. Your textbook is NOT primary authority
nor are IRS Publications. Please refer to Chapter 2 for primary authorities. CCH AnswerConnect is not a primary
authority, nor is Google Scholar nor are any other websites you may access. The primary authorities are legislative,
administrative and judicial. I will attach the Chapter 2 for primary authorities in the thread.

I HAVE ATTACHED EXAMPLES OF THE MEMOS

You must use proper citation form in your memo (see Chapter 2 for help with citation form). The form for this
communication should be professional and in the form of a tax research memo (examples posted on Canvas and a
similar example in your textbook). You will see that citations are within the text of the document in the example.
Once a court case has been cited in full, it can be referred to using simply the name in italics.

-This memo should be whatever length you feel is appropriate to resolve the issues. We do NOT use a bibliography
or list of references in a tax research memo. We do not include Background in a tax memo. The Background is
provided so you can identify the facts.

POINTS DISTRIBUTED:

Aspects of the memo Points
Content – facts and issue(s) 16
Content – analysis 30
Content – conclusion 14
Organization 8
Audience 8
Style 8
Mechanics 8
Referencing 8
Total 100


RUBRIC:

Tax memo rubric

Criteria Ratings Pts

This criterion is linked to a Learning OutcomeContent – Facts and issuesAll pertinent facts and issues have been described in a clear and concise manner. Distinguishing features of the fact pattern are highlighted.

16 pts

Full Marks

14 pts

Good

13 pts

Fair

Most critical facts and issues identified and communicated. Some unessential facts included.

11 pts

Needs work

10 pts

Poor

Critical facts and issues omitted or substantial unessential facts and issues included. Unable to apply or distinguish from other possible fact patterns or facts are merely copied from case.

0 pts

Little or no effort

Does not meet minimum requirements for effort

16 pts

This criterion is linked to a Learning OutcomeContent – AnalysisAll necessary references to authority have been made. Authority which could apply but does not has been distinguished from that which does. The analysis follows a logical pattern of application to the facts and supports author?s conclusion.

30 pts

Full Marks

All necessary references to authority have been made. Authority which could apply but does not has been distinguished from that which does. The analysis follows a logical pattern of application to the facts and supports author?s conclusion.

27 pts

Good

24 pts

Fair

Analysis is incomplete or one-sided. Most relevant authority has been identified. Analysis is not perfectly logical or does not support issue stated.

21 pts

Needs work

18 pts

Poor

Analysis is deficient in reference to authoritative tax law. Analysis lacks cohesion and does not support conclusion. Analysis relies on secondary sources when primary sources exist.

0 pts

Little or no effort

Does not meet minimum requirements for effort

30 pts

This criterion is linked to a Learning OutcomeContent – ConclusionConclusion is clear and integrates with facts and analysis. More than a simple sentence stating conclusion. Cause and effect relationship between facts and analysis are made. All open issues are responded to. Conclusion drawn is correct.

14 pts

Full Marks

13 pts

Good

11 pts

Fair

Conclusion fails to tie analysis and facts together. Some conclusions made as part of analysis instead of in conclusion.

10 pts

Needs work

8 pts

Poor

Conclusion is unclear and unsupported by analysis. Reader is not able to form educated opinion on tax treatment of facts pattern. Conclusion is a simple sentence stating conclusion.

0 pts

Little or no effort

Does not meet minimum requirements for effort

14 pts

This criterion is linked to a Learning OutcomeOrganizationPaper flows well with appropriate beginning, development, and conclusion. Paragraph structure contributes to flow and transitions. Organization and/or headings help the reader to understand and remember information.

8 pts

Full Marks

Paper flows well with appropriate beginning, development, and conclusion. Paragraph structure contributes to flow and transitions. Organization and/or headings help the reader to understand and remember information.

7 pts

Good

6 pts

Fair

Paper follows logical sequence with identifiable beginning, development, and conclusion. Generally proper use of paragraph structure and topic sentences. Organization and/or headings help the reader to follow and find information.

5 pts

Needs work

4 pts

Poor

Paper lacks logical sequence hence causing format to interfere with readability. Does not use proper paragraphing. Topic sentences do not lead to rest of paragraph or are missing altogether.

0 pts

Little or no effort

Does not meet minimum requirements for effort

8 pts

This criterion is linked to a Learning OutcomeAudienceWriter clearly focuses writing to the audience, and displays empathy for the reader. Goodwill is created through consideration of the reader?s needs. Message tailored directly for the reader

8 pts

Full Marks

Writer clearly focuses writing to the audience, and displays empathy for the reader. Goodwill is created through consideration of the reader?s needs. Message tailored directly for the reader

7 pts

Good

6 pts

Fair

Writer acknowledges the reader and displays some thought about the nature of the audience. Reader is treated politely and positively. No evidence of inappropriate attitude.

5 pts

Needs work

4 pts

Poor

Writer is internally focused rather than focused on the reader. No clear awareness or understanding of the audience is evident. Writer may appear discourteous to the reader.

0 pts

Little or no effort

Does not meet minimum requirements for effort

8 pts

This criterion is linked to a Learning OutcomeStyleDemonstrates a sophisticated grasp of the language in terms of both sentence structure and vocabulary. Writes fluidly and concisely. Includes appropriate business terms.

8 pts

Full Marks

Demonstrates a sophisticated grasp of the language in terms of both sentence structure and vocabulary. Writes fluidly and concisely. Includes appropriate business terms.

7 pts

Good

6 pts

Fair

Sentences vary in length and style. Strong action verbs are used. Occasionally uses jargon or clichés. Vocabulary and word usage generally is correct and shows some variety. Uses business terms appropriately.

5 pts

Needs work

4 pts

Poor

Overuse of simple sentences. May misuse words or idioms. May include slang. Wordy rather than concise. Writing shows lack of sophistication or variety in vocabulary. Awkward. Little or no use of business terms.

0 pts

Little or no effort

Does not meet minimum requirements for effort

8 pts

This criterion is linked to a Learning OutcomeMechanicsNo errors in word usage, sentence structure (run-ons, fragments), spelling, punctuation, and capitalization. Strong mechanics help to establish credibility.

8 pts

Full Marks

No errors in word usage, sentence structure (run-ons, fragments), spelling, punctuation, and capitalization. Strong mechanics help to establish credibility.

7 pts

Good

6 pts

Fair

Relatively free of errors in word usage, sentence structure (run-ons, fragments), spelling, punctuation, and capitalization. Mechanics do not detract from credibility of the content.

5 pts

Needs work

4 pts

Poor

Significant errors in word usage, sentence structure (run-ons, fragments), spelling, punctuation, and capitalization. Errors undermine credibility of content and readability.

0 pts

Little or no effort

Does not meet minimum requirements for effort

8 pts

This criterion is linked to a Learning OutcomeReferencingReferences (if called for) are consistently correct. No missing citations.

8 pts

Full Marks

References (if called for) are consistently correct. No missing citations.

7 pts

Good

6 pts

Fair

Generally correct referencing (if called for).

5 pts

Needs work

4 pts

Poor

References (if called for) are missing or do not use correct referencing style.

0 pts

Little or no effort

Does not meet minimum requirements for effort

8 pts

Total Points: 100

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