The example uses a different case. Your submission should not be more than 7 pages long. 

Use the attached file to find the case you have been assigned.

Purpose:  The purpose of this is to enable you to meet the following goals:

• Understand the role of a tax practitioner
• Identify the tax issues involved in a scenario
• Be able to conduct comprehensive tax research utilizing on-line tools in order to formulate a solution to the issues raised.
• Be able to articulate and defend a tax position in writing.

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

• 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.

The writing assignment will be graded based on grammar, style of writing, logical development of ideas, critical thinking skills, and technical accuracy of the analysis and conclusions, using a rubric, which is found below. 

Assignments will be evaluated on:

• Completion of assigned task (instructions)
• Quality of content and research
• Presentation of material