Your manager directs you to find and document time spent by Rickey relating to running RRBB. You discovered that Rickey estimates that he spent about 80 hours on RRBB matters this year. This time primarily included various meetings with trust employees in which they updated Rickey about RRBB operations. Rickey also helped to interview a new boatbuilder who RRBB later hired. In addition, after contacting the RRT, you learn that trust employees spent over 1,000 hours running RRBB during the year.

Re-read and think about the facts that we now know for Rickey, the RRT, and RRBB.

 

 

1. Using the current Internal Revenue Code (IRC) as your authority, list the IRC section(s) that you think might bear on the answer to their issues. You will consult other authority in Modules 4 and 5, so restrict your inquiry to the IRC.

 

2. What do the IRC section(s) you listed above say about these tax issue(s)? To answer this question, write a tentative Law section of your FILAC memo using only the IRC as your primary authority. In addition, revise the Facts and/or Issues sections now that you know additional facts. Submit the Facts, Issues, and (incomplete) Law section of memo.

 

3. After reading the IRC, what tax issue(s) remain unresolved? What additional information do you need from the client to resolve these issues, if any?