I need help with my Tax memo for my Taxation class. The details consist of:
-Prepare a tax research memo addressing the question that has been raised.Please note that if the tax memo is not in the required format and/or contains very little analysis you will receive a zero (0) for the assignment. All good faith efforts are capable of receiving a minimum of 60% but less than a good faith effort will be awarded zero points.
–You will need to support your conclusion using primary sources of tax law. Your textbook is NOT primary authority nor are IRS Publications. Please refer to Chapter 2 for primary authorities. CCH AnswerConnect is not a primary authority, nor is Google Scholar nor are any other websites you may access. The primary authorities are legislative, administrative and judicial. I will attach the Chapter 2 for primary authorities in the thread.
I HAVE ATTACHED EXAMPLES OF THE MEMOS
–You must use proper citation formin your memo (see Chapter 2 for help with citation form). The form for this communication should be professional and in the form of a tax research memo (examplesposted on Canvasand a similar example in your textbook). You will see that citations are within the text of the document in the example. Once a court case has been cited in full, it can be referred to using simply the name in italics.
-This memo should be whatever length you feel is appropriate to resolve the issues. We do NOT use a bibliography or list of references in a tax research memo. We do not include Background in a tax memo. The Background is provided so you can identify the facts.
POINTS DISTRIBUTED:
Aspects of the memoPoints Content – facts and issue(s)16 Content – analysis30 Content – conclusion14 Organization8 Audience8 Style8 Mechanics8 Referencing8 Total100
RUBRIC:
Tax memo rubric
Criteria
Ratings
Pts
This criterion is linked to a Learning OutcomeContent – Facts and issuesAll pertinent facts and issues have been described in a clear and concise manner. Distinguishing features of the fact pattern are highlighted.
16 pts
Full Marks
14 pts
Good
13 pts
Fair
Most critical facts and issues identified and communicated. Some unessential facts included.
11 pts
Needs work
10 pts
Poor
Critical facts and issues omitted or substantial unessential facts and issues included. Unable to apply or distinguish from other possible fact patterns or facts are merely copied from case.
0 pts
Little or no effort
Does not meet minimum requirements for effort
16 pts
This criterion is linked to a Learning OutcomeContent – AnalysisAll necessary references to authority have been made. Authority which could apply but does not has been distinguished from that which does. The analysis follows a logical pattern of application to the facts and supports author’s conclusion.
30 pts
Full Marks
All necessary references to authority have been made. Authority which could apply but does not has been distinguished from that which does. The analysis follows a logical pattern of application to the facts and supports author’s conclusion.
27 pts
Good
24 pts
Fair
Analysis is incomplete or one-sided. Most relevant authority has been identified. Analysis is not perfectly logical or does not support issue stated.
21 pts
Needs work
18 pts
Poor
Analysis is deficient in reference to authoritative tax law. Analysis lacks cohesion and does not support conclusion. Analysis relies on secondary sources when primary sources exist.
0 pts
Little or no effort
Does not meet minimum requirements for effort
30 pts
This criterion is linked to a Learning OutcomeContent – ConclusionConclusion is clear and integrates with facts and analysis. More than a simple sentence stating conclusion. Cause and effect relationship between facts and analysis are made. All open issues are responded to. Conclusion drawn is correct.
14 pts
Full Marks
13 pts
Good
11 pts
Fair
Conclusion fails to tie analysis and facts together. Some conclusions made as part of analysis instead of in conclusion.
10 pts
Needs work
8 pts
Poor
Conclusion is unclear and unsupported by analysis. Reader is not able to form educated opinion on tax treatment of facts pattern. Conclusion is a simple sentence stating conclusion.
0 pts
Little or no effort
Does not meet minimum requirements for effort
14 pts
This criterion is linked to a Learning OutcomeOrganizationPaper flows well with appropriate beginning, development, and conclusion. Paragraph structure contributes to flow and transitions. Organization and/or headings help the reader to understand and remember information.
8 pts
Full Marks
Paper flows well with appropriate beginning, development, and conclusion. Paragraph structure contributes to flow and transitions. Organization and/or headings help the reader to understand and remember information.
7 pts
Good
6 pts
Fair
Paper follows logical sequence with identifiable beginning, development, and conclusion. Generally proper use of paragraph structure and topic sentences. Organization and/or headings help the reader to follow and find information.
5 pts
Needs work
4 pts
Poor
Paper lacks logical sequence hence causing format to interfere with readability. Does not use proper paragraphing. Topic sentences do not lead to rest of paragraph or are missing altogether.
0 pts
Little or no effort
Does not meet minimum requirements for effort
8 pts
This criterion is linked to a Learning OutcomeAudienceWriter clearly focuses writing to the audience, and displays empathy for the reader. Goodwill is created through consideration of the reader’s needs. Message tailored directly for the reader
8 pts
Full Marks
Writer clearly focuses writing to the audience, and displays empathy for the reader. Goodwill is created through consideration of the reader’s needs. Message tailored directly for the reader
7 pts
Good
6 pts
Fair
Writer acknowledges the reader and displays some thought about the nature of the audience. Reader is treated politely and positively. No evidence of inappropriate attitude.
5 pts
Needs work
4 pts
Poor
Writer is internally focused rather than focused on the reader. No clear awareness or understanding of the audience is evident. Writer may appear discourteous to the reader.
0 pts
Little or no effort
Does not meet minimum requirements for effort
8 pts
This criterion is linked to a Learning OutcomeStyleDemonstrates a sophisticated grasp of the language in terms of both sentence structure and vocabulary. Writes fluidly and concisely. Includes appropriate business terms.
8 pts
Full Marks
Demonstrates a sophisticated grasp of the language in terms of both sentence structure and vocabulary. Writes fluidly and concisely. Includes appropriate business terms.
7 pts
Good
6 pts
Fair
Sentences vary in length and style. Strong action verbs are used. Occasionally uses jargon or clichés. Vocabulary and word usage generally is correct and shows some variety. Uses business terms appropriately.
5 pts
Needs work
4 pts
Poor
Overuse of simple sentences. May misuse words or idioms. May include slang. Wordy rather than concise. Writing shows lack of sophistication or variety in vocabulary. Awkward. Little or no use of business terms.
0 pts
Little or no effort
Does not meet minimum requirements for effort
8 pts
This criterion is linked to a Learning OutcomeMechanicsNo errors in word usage, sentence structure (run-ons, fragments), spelling, punctuation, and capitalization. Strong mechanics help to establish credibility.
8 pts
Full Marks
No errors in word usage, sentence structure (run-ons, fragments), spelling, punctuation, and capitalization. Strong mechanics help to establish credibility.
7 pts
Good
6 pts
Fair
Relatively free of errors in word usage, sentence structure (run-ons, fragments), spelling, punctuation, and capitalization. Mechanics do not detract from credibility of the content.
5 pts
Needs work
4 pts
Poor
Significant errors in word usage, sentence structure (run-ons, fragments), spelling, punctuation, and capitalization. Errors undermine credibility of content and readability.
0 pts
Little or no effort
Does not meet minimum requirements for effort
8 pts
This criterion is linked to a Learning OutcomeReferencingReferences (if called for) are consistently correct. No missing citations.
8 pts
Full Marks
References (if called for) are consistently correct. No missing citations.
7 pts
Good
6 pts
Fair
Generally correct referencing (if called for).
5 pts
Needs work
4 pts
Poor
References (if called for) are missing or do not use correct referencing style.
