Tax Research Problem

RESEARCH PROJECT
Assignment
Your assignment is to provide a written answer to the Tax Research Problem assigned from Chapters of the South-Western Text.
Format
Your answer should be no more than 2-3 pages (approximately 250 words per page) typed in a word processing program. The answer should be structured in memorandum form as follows.
A completed Taxation Project with the file name “Sample Falcon Charitable Deduction 08182023” is posted.

TO: File of (taxpayer name). (Your audience is other CPAs in your firm as peer review.)
FROM: (your name)
RE: (state issue) (issue is stated in the separate Tax Research Problem posted in the course and/or attached to email from this professor)
DUE: (due date)
CONCLUSION: (short statement)
REASONING: (body) (generally in your own words; some quotes may be appropriate)
state the facts of the taxpayer in the assigned problem
state the rules of law from, e.g., case(s), and/or IRS rulings and pronouncements, and/or the Code, and/or Regulations, etc.
show your reasoning (apply the law to the facts of the taxpayer in the assigned problem)
conclusion repeated
Attach 1 page from CCH and 1 page from Westlaw (plus the “History” from Westlaw) to show that you were able to locate appropriate primary authority. Usually, the professor provides some guidance in the specific Tax Research Problem posted and/or emailed as to what item of authority (e.g., a case or Revenue Ruling) may be the most appropriate. The closer any facts in the authority, which you locate, are to the facts in the Tax Research Problem, the more appropriate that authority is for resolving the issue of the Tax Research Problem. The same authority should be located in CCH and Westlaw. Even if a internet search engine is used, CCH and Westlaw must be used. In real life the entire most appropriate authority and other related materials might be attached.

Suggested Research Sources and Citation Format
CCH AnswerConnect and Westlaw are available on-line on campus through the Pfau library or from elsewhere. (These sources should be sufficient.) The San Bernardino Law Library (885-3020) and the Riverside Law Library, 3989 Lemon (275-6390), are open to the public. Please call for hours.
If the law libraries are used, the sources most likely to be useful are BNA’s Tax Management Portfolios (Income Tax) and possibly RIA. Citations should be in the format the text uses in its footnotes as, for example, in Chapter 2. The text’s citations would be acceptable in practice and are loosely based on the most appropriate book on the form for legal citations, A Uniform System of Citation. For the format in that book, see also websites such as http://www.law.cornell.edu/citation/ or http://www.scu.edu/lawreview/bluebook.htm and see http://www.americanbar.org/content/dam/aba/publishing/tax_lawyer/ttlstyle.authcheckdam.pdf
In a memorandum, citations usually appear in the text preceding or following statements which the citations support, either as a part of the sentence or as a separate citation sentence, if the citation follows a statement. Citations are in footnotes in a research piece such as a law review article or in a textbook. Please do not surround citations with [brackets] as in the textbooks’ examples.
RESEARCH PROBLEM
(from South-Western Federal Taxation)

Issue: Is the violin which Gabriella, a concert violinist, has purchased for $80,000 subject to 179 expensing, bonus depreciation, and/or MACRS depreciation?
(Locate the most appropriate I.R.S., court, and/or I.R.C. guidance. Likely, one or more Tax Court cases will be the most appropriate authority for this particular Research Problem. Of course, a court case may be the most appropriate authority when it interprets, for example, I.R.C. sections and has similar facts to the facts of the taxpayer in this Tax Research Problem.)

Facts:
Professor Gabriela teaches violin at the University. She is also a concert violinist. She purchased a violin for $80,000.
Grading
Your grade will be based on:
(a) Content – correct tax reasoning and result, reached using appropriate authority (The closer any facts in the authority, which you locate, are to the facts in the Tax Research Problem, the more appropriate that authority.)
(b) Style – easy to read, professional business usage (as in the various sample memoranda mentioned)
(c) Grammar – correct basic English usage: spelling, punctuation, avoiding run-on sentences, etc.