1. Use RIA Checkpoint to research and complete this assignment. Use Chapter #2 of your textbook as a reference as you work on this project. 2. Write a Research Memorandum to convey your conclusions. See Exhibit 2-9 of your textbook for a sample memorandum. Make sure you prepare a Research Memorandum NOT a Client Letter. 3. The memo must be in proper form: - A concise statement of pertinent facts. - An identification of all tax issues (include list of authorities used). - Your conclusions. - A thorough discussion of the reasoning (analysis) upon which your conclusions are based. - Citations, in proper form, to all primary authority relied on in reaching your conclusion, e.g., code sections, reg. sections, court case, revenue ruling, etc. 4. Any primary authority discussed in your memorandum must be tied into the facts of this particular assignment. Do not merely recite the law without explicitly relating it to the facts at issue. 5. Secondary authority may NOT be cited in your memorandum. It should only be used to help you find relevant primary authority. 6. Your memorandum must be typed. Your paper must be double-spaced. 7. Your grade will be based on the following: - How well you performed the research, e.g., did you locate, cite, and discuss the relevant law. - The quality of your written communication. - The quality of your discussion of the issues. - Your conclusions. 8. At a minimum your memorandum should cite: Two Internal Revenue Code sections. Two court cases (at least one of the cases should be a circuit court case). Since you are not being given residence information, you may use a circuit court case from any circuit. One other primary source, e.g., revenue ruling, revenue procedure, notice, etc. Do not use another case or Internal Revenue Code section for this requirement. Important: 1. You may discuss your conclusions and rationale for such conclusions with your classmates. However, you must perform your own research and write your own memorandum without input from other students. Do not allow other students to read your memorandum. 2. Do not copy and paste any language from any sources into your memorandum. TAXPAYER INFORMATION . Danny, an avid college basketball fan, has always purchased his tickets from online ticket sites and ticket scalpers. However, this year he was invited to join the universitys ticket program. The program requires a $7,500 contribution to the university for the privilege or right to purchase season tickets. Participants in the program then pay $1,000 per season ticket. How much, if any, of the $7,500 and $1,000 payments is deductible? (assume that Danny itemizes deductions and would not be limited by any AGI limitation, if applicable)