The reviewer does not need this additional information since, under Tax research memo method we recommend, the authoritative support is provided in Section B. Taxpayers often allocate items on the basis of common sense or sound logic.
Another possibility is that the researcher meant to refer to a qualified receipt rather than a determination letter. Supporting cites should be to primary sources, except in rare, unusual situations.
In fact, avoid the temptation to highlight large portions of the page; try to narrow it down to one or two sentences or a few lines.
To be expandable, the system should allow for additional pages to be added later without renumbering existing pages. The tax professional should provide complete and specific cites.
Support material in Section B should be arranged in order of authoritative weight. In this issue, the regulation provides some clarification but is insufficient to resolve the issue and reach a conclusion.
The traditional cite, which includes the volume, reference to the Cumulative Bulletin, and page number, provides unnecessary information that clutters the research memo.
Do not force the reviewer to interpret the tax authority, wonder how your cited authority relates to the issue, or otherwise guess your line of reasoning. The endnotes provide information that will help you to think about what Albert wrote and why.
An explicit application of law to facts is very important in a research memo. Deduction for AGI is a more favorable outcome for many taxpayers than an itemized deduction, which the next paragraph addresses.
Generally, you should discuss each judicial decision or ruling briefly to show its relevance; the example here is an exception to this usual procedure. Not only does this information provide ease of reference, but it allows pages that become separated to be reunited with the correct file or research memo.
Though additional facts might be incorporated through cross reference from section A of the research memo, it is often preferable to weave all facts together so that they reside in one location and are organized so that related facts are together.
For example, Jones v. In addition, the preparer should date and initial all pages in Section A e. For example, if two pages must be inserted later between pages B-6 and B-7, they could be numbered B-6a and B-6b.
The same is true of IRS rulings. After the research has begun, the tax professional may realize the need for additional facts or clarifications, which might be obtained through a follow-up telephone conversation, e-mail correspondence, or a formal letter.Tax Research Memo #1 Prepare tax research memorandum for the case below.
You should conduct some preliminary tax research (suggest you use topical indices such as the Master Tax Guide and/or the. Writing a tax research memo is an art. Tax professionals do not universally use the same techniques.
Generally, the more. View Notes - Tax Research Memorandum - Example from ACCOUNTING at University of Wisconsin. Tax Research Memorandum To: Date: By: Re: John Davis January 24, Student (Put your name on the%(34). Writing Tax Research Memos BA Individual Tax Purposes To find a solution to the tax problems of one’s clients or employer • To organize the.
The tax research memo on this web site illustrates one way in which tax research can be documented and communicated.
Before reviewing this memo, study the lesson for writing a research memo, read. (Income Tax & Accounting) This memo addresses whether fees paid by issuers of certain health insurance policies Outcomes Research Trust Fund.Download