This two-part assignment introduces you to the fundamentals of conducting tax research and preparing a tax memo. Tax research memos generally outline the facts, issues, conclusions, and analysis of a tax case. In Part 1, if you were assigned, you practiced writing the facts and issues for Sarah Johnson’s case, and how to navigate and cite authorities. You will now complete Part 2 by learning how to write the conclusion and analysis sections and complete a final draft of Sarah Johnson’s tax memo.

Instead of a final quiz, you will use your draft of the facts and issues sections to prepare and submit a final tax memo draft, including the conclusion and analysis. This final draft will be reviewed and evaluated by generative AI (GenAI).

Note: To complete Part 2, you will rely on a pdf copy of your drafted facts and issues prepared in Part 1. If needed, you will download this pdf on Page 1 of this assignment. If you were not assigned Part 1, your instructor should have provided you with an example draft.

Learning objectives

1. Identify the relevant IRC and Treasury Regulation authority for each issue, both with and without generative AI (GenAI) assistance.
2. Write a structured tax analysis applying tax law to the client’s specific situation and facts.
3. Cite the primary authority correctly using in-text formatting.
4. Write clear, defensible conclusions that support and answer each issue.
5. Prepare a complete, professionally formatted tax memo.

Suitable courses: Tax

You must have an account with EYARC Experience and then go to the Assignment Catalog to review