The project will consist of conducting further research on the court cases. For example, if the issue decided by the court is “whether interest income on tax exempt bonds is excludable from gross income.” Then you will conduct further research to locate other court cases, revenue rulings, revenue procedures, technical advise memorandums, private letter rulings, etc. authorities that also address that issue. Locate and analyze a minimum of five authorities for the court cases provided to you.
1. 4 page type-written(12pt. Times New Roman) memorandum summarizing the authorities located for the court case.
2. The summary should include the authority used (for example the name of the court case, revenue ruling, internal revenue code section, etc.)
3. Also include a brief description of issue, facts, and the ruling of the court.
4. Must include a discussion of how the cases relate to the cases assigned to you. For example, you may discuss the similarities or differences in the facts or holding of each case.
5. Additionally, if you locate a revenue ruling or revenue procedure that is on point, you should describe how the ruling or procedure applies to your issue.
In the conclusion, include “how did the court rule? Why?” and your comments.
NOTE: Please do not address penalties.
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