Assume that you are a staff accountant working in the tax department of a Big 4 accounting firm. The
senior accountant in your firm approaches you with a tax issue asking you to do some tax research.
Prepare a detailed Tax Memorandum analyzing a specific tax scenario using Primary Federal Tax
Law sources only. Please write a tax memo to the senior accountant for one of the two research
problems below:
Research Problem 1 on page 5-41 (Murray whistle blower) (Problem will be highlighted and attached in additional materials).

Writing Requirements:
ü Tax memos are short – no need to include separate headings. Please refer to Figure 2.6 and 2.7
in chapter 2 for examples of tax file memorandum.
ü The memo should be at least 1 page but no more than 2 pages (single-spaced).
ü Your memo should include separate paragraphs with a discussion about the relevant facts and
tax issues, citation of relevant code sections, one court case, and your conclusion.
ü Provide clear and logical arguments for your conclusion. Your arguments will be supported by
the relevant IRC and the court case.
ü Be sure to read the relevant chapter before completing the assignment. The textbook chapter
cites relevant code sections that you may want to look up and mention in your tax memo.
o Find one court case with similar circumstances and discuss the case briefly in your
memo to support your conclusion. Explain how the court case is similar to the relevant
facts of your client (i.e., the court case needs to discuss the same tax issue as your
clients’). The court case you find has to involve the IRS, the Commissioner, United
States as one of the parties. The case has to involve a tax issue.
ü Clearly answer the question in the problem.
ü No need to include Reference page. You need to include the citation of the primary tax law
source within the memo.
Tax research involves the following procedures:
1. Identify the tax issue
2. Discuss relevant facts and transactions
3. Identify appropriate tax law sources – cite primary sources only; include a court case examining
similar tax research question
4. Provide your conclusions and support your analysis with clear and logical arguments
5. Discuss any assumptions made in arriving at the solution
Tax Research Resources:
· Recommended: CSUSM Kellogg Library has RIA Checkpoint database. Your books also come
with instructions and an access code to RIA Checkpoint. RIA is used by many public
accounting firms.

Other web sites that may be useful are:
· Cornell University Law School web site has the IRC:
· IRS web site: WWW.irs.gov
· Court opinions: WWW.law.justia.com
· You will be graded on the thoughtfulness of your discussion as well as on the writing quality.
· You will be graded on the persuasiveness of your arguments and whether your arguments are
well-supported by a tax court case and IRC.
· Proofread your paper for spelling and grammatical errors, and also check whether the paper
reads well. Consult a dictionary and/or a style manual for spelling and grammar problems.
· Avoid one-sentence paragraphs. By definition, a paragraph is a group of sentences constructed
around a central topic.
· Avoid contractions. Business reports (tax memos) should not use contractions. For example,
use “should not” instead of “shouldn’t.”
· Try to use the active voice rather than the passive voice. For example, instead of writing “This
case was decided by the Tax Court”, write, “The Tax Court decided this case.” Papers written
in the active voice read easier, and using the active voice also conserves words.
· Nouns and their modifying pronouns must agree. An example of incorrect grammar: “The
Supreme Court ruled in favor of the government. They rejected the argument of the taxpayer.”
“Court” is a singular noun while “they” is a plural pronoun