When the issue is written unclearly or ambiguously, the tax professional may research the wrong issue. Some issues cannot be addressed until other issues are resolved first. Another common mistake is to emphasize financial accounting concepts, such as net income and expense, rather than the analogous tax concepts, namely gross income and deduction.
For example, the dollar amount of the fines is used in the issue.
Please read the fact scenario that we provide for practice, complete the research, and write a research memo following the lesson guidelines. A methodological memo is a kind of research memo that Tax research memo example focused on the assessment of methodology used within the entire research process.
In this case, paging for Reg. Organization is the key ingredient.
Consider the example below, which involves the statutory law: Listing authoritative support in a logical order mitigates the desirability or necessity to include a table of contents or similar guide to the support materials in Section B, especially when this section is lengthy.
What is the tax treatment for a company under Reg. Deduction for AGI is a more favorable outcome for many taxpayers than an itemized deduction, which the next paragraph addresses.
Expanding on the example above, consider the following: When authoritative support e. The photocopied support materials that appear in Section B must include the full text beginning to end of any Code section, regulation, ruling, or judicial decision cited.
If it narrows the focus or clarifies the statutory law, discuss any related regulation next. In contrast, the issue in a judicial brief should be written in more general terms.
Clear written communication is important since tax planning ideas or IRS audits can cause prior tax returns to be amended or adjusted long after originally filed. An explicit application of law to facts is very important in a research memo. To be expandable, the system should allow for additional pages to be added later without renumbering existing pages.
Facts often are gathered at different times and through different means. The presentation of research findings and conclusions should not resemble a mystery novel. Taxpayers often allocate items on the basis of common sense or sound logic. Alternatively, the researcher may wish to know whether the contribution John made is deductible.
Abbreviate very common tax terms as appropriate, especially in cites. The court held that the one event was so significant that it constituted a U. Look at the examples below, the first of which, if taken literally, involves the non-tax issue of how to report a payment for financial statement purposes: As appropriate, express issues in the context of major tax concepts like gross income, capital gain, exclusion, deduction, credit, and basis.
The traditional cite, which includes the volume, reference to the Cumulative Bulletin, and page number, provides unnecessary information that clutters the research memo. Under the method we recommend, the research memo contains two parts: If a regulation adds further insight, discuss its contribution next.
Under the method we recommend, the tax researcher provides authoritative support in Section B for positions taken in Section A. If so, this question of fact should be verified through contacting the organization.
The support materials, which are essentially attachments to Section A, are primary sources of the tax law e. Sometimes an issue requires that several subpoints be addressed e. Likewise, citations to Revenue Rulings should not include the volume and page number. However, avoid the temptation to abbreviate many words or phrases beyond those that are commonly accepted.
Thus, Section A cites to judicial decisions should include only the title, court, and year of the decision. Clearly stating facts is particularly important when more than one person is involved in the research project.
How much can a taxpayer deduct for money donated to her church last year? Do not expect the reviewer to wade through several highlighted sentences or paragraphs to find the specific passage that you reference.Example of a Tax Research Memo The tax research memo on this web site illustrates one way in which tax research can be documented and communicated.
Before reviewing this memo, study the lesson for writing a research memo, read the fact scenario we provide, complete the research, and write a research memo following the lesson guidelines.
9 Research Memo Examples & Samples A research memo is a formal note or tool used to answer questions that are necessary in assuring that the content of a research document used by an organization is well interpreted and understood. Writing Tax Research Memos BA Individual Tax Purposes To find a solution to the tax problems of one’s clients or employer • To organize the facts, issues, and conclusions of the project To facilitate a review of the research activities by colleagues To allow for subsequent examination of the research issue Audience Users: are well versed in federal tax law understand frequent and.
Unfortunately, this often leaves little time to spend hours conducting tax research. This is where I come in.
When you’ve got a tax question, I’m there to answer it for you. Depending on the question, I may write a formal memo but for others an email exchange or phone call will suffice.
You can check out my work with these sample. Tax Research Memorandum To: John Davis Date: January 24, By: Student (Put your name on the back of this Memorandum) Re: Deductible payments in FACTS The relevant facts of the situation are as follows: 1.
John Davis operates a consulting business which reports on %(35). Tax Research Memorandum Date: To: From: Subject: September 28, Tax Files Johnny Appleseed Taxability of Gambling Gains/Losses and Business Expenses Summary of Facts Stephen Colbert is a 5/5(1).Download