In this assignment, you will reverse engineer a tax memo from a court case. I have enclosed a sample tax memo format for you to follow.

Sample Memo Format  

Research Problem 

Instructions: 

1.  The code section should relate to partnership distributions, transfers of interests, sales, or terminations. 
2. Locate the Internal Revenue Code Section that governs the topic of your choice. 
3. Search a tax research database (CCH, BNA, etc.) for a court case involving your topic and code section of choice. 
4. Read the court case and familiarize yourself with the parties involved, facts surrounding case, etc. 
5. Synthesize your court case into a tax memo.