Research any tax court cases that are similar to the research problem you selected

1. Perform your own research to obtain as much information on the case as possible.  Do NOT just rely on Google (the results may not always be the most current).  You also have a free tax research subscription with your text.  Consider the following in your research
   1. Does the IRS have a specific publication or guidance on this topic?
   2. Research any tax court cases that are similar to the research problem you selected
   3. Are there CPA or tax Attorney blogs that cover this area
2. Prepare a Tax File Memorandum (use Exhibit 2.9 from the text for guidance)
   1. Note – there is no minimum or maximum amount of words.  I am looking to see if you were able to perform sufficient research to document your understanding of the issue.  Do NOT just copy what you find from your research – you need to have the analysis in your own words or you will lose points.
3. Prepare a Client Letter (use Exhibit 2.10 from the text for guidance)
   1. Note:  This letter needs to be in a format that a client would understand – do NOT just copy the results of your tax file memorandum in the letter.
   2. The letter needs to be long enough to get your point across but make sure it is clear and concise
4.  Provide me a list of sources you used to obtain your information (website address, published articles, etc).

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