Task: In order to successfully complete this assignment you must:

Individually prepare a memorandum to the tax manager outlining the information you found in your research.

Format the memo to include:

Restatement of Facts $($paraphrase$)$

Identify at least three main issues based on these facts

Provide a conclusion for each issue

Include the analysis that led you to the conclusion for each issue. This analysis should refer to the primary authority that best addresses the issue.

Primary authority would include items such as the Internal Revenue Code, Regulations, Court Cases, etc. These also should be paraphrased in order to highlight your understanding of the primary authority and how it relates specifically to the issue. Tax Topics and IRS publications are NOT primary source material.

Submit the assignment using a Turnitin assignment dropbox.

Turnitin, is an online resource that checks your work against: the submissions of others, books, articles, tax code, etc., in order to verify originality of your content. Given that everyone in the course is working on the same problem and using the same format, the service will likely find some similarity in your paper. Upon submission you will be able to see your score immediately, as others submit their papers your score may increase. Should you resubmit your paper, the originality score will not be viewable for $12-24$ hours.

I use the information supplied by TurnItIn as well as my professional judgment to determine the originality of your paper. A high similarity rating is an indication of either plagiarism or insufficient original content on your part. Plagiarism is a serious violation of the student's code of conduct and will be handled by the Student Affairs office.

I will accept late assignments for no more than $48$ hours after the due date, with a $20\%$ penalty.