The preparation of an effective and efficient tax research memorandum requires a thorough analysis of the issue, facts, and authoritative rule, statement, or regulation to determine an appropriate conclusion, just as with a traditional research paper. During your time at Franklin, you have undoubtedly become very familiar with the “IRAC” method or format for research papers consisting of 4 general parts:
Utilizing this type of structured analysis helps you to focus on your writing, resulting in a more effective and well-reasoned paper. You will be using a slightly modified version of the IRAC model or structure in completing this assignment. While the type of structured, rules-based analysis you will be doing is the same, it will be structured in a format more traditionally used by accountants and other professionals.
Focusing on your assigned research problem, prepare an effective and efficient tax research memorandum providing a thorough analysis of the issue, facts, and authoritative rule, statement, or regulation to determine an appropriate conclusion.
The analysis is the substantive portion of your memorandum and is worth the majority of the points on the assignment. It is where you present all of the analysis that is required to support your conclusion. Once you have identified the issue or issues that you have to resolve to answer, you will need to perform tax research to identify tax authorities to establish the controlling “rule” that resolves those issues. Your analysis for each of these issues should review these authorities and then apply them to the facts of the case to draw conclusions.
Apply the “IRAC” method or format for research papers.
The memo should be 2-3 pages, double-spaced, size 12 font.
Demonstrates proper IRAC format and tax law citation.
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