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Performing tax research to find correct answers to a given tax situation and composing memorandums summarizing these findings are important parts of tax practice. As outlined in Chapter 2 of your text, there are several authoritative primary tax law sources. The first, the Internal Revenue Code, is the law enacted by Congress. The Treasury Department and the Internal Revenue Service publish a number of materials that interpret and provide decisions, pronouncing their interpretation and application of the Code, including treasury regulations, revenue rulings, and revenue procedures. Finally, courts are often asked to hear tax disputes between taxpayers and the United States, and these courts issue rulings that interpret and apply the tax law, creating additional tax authority in the process. These combined writings constitute primary tax law authority, and these are the authorities that tax practitioners rely upon when a client asks for their opinions regarding how a proposed or a completed transaction should be treated for tax purposes.

In this project, you will be presented with two tax research problems and asked to answer the questions pertaining to the facts presented in each Fact Pack:

  • Kenny’s Fact Pack
  • Blough’s Fact Pack

For both Fact Pacts, you will need to:

  • Read and analyze these authorities,
  • Apply their holdings to the facts you are given,
  • Conclude how the transaction you are given should be treated for tax purposes.

In Kenny’s Fact Pack, you are asked to:

  • Discuss the facts,
  • Identify and discuss the issues, and
  • Provide a thorough analysis, based on the facts presented.  

In Blough’s Fact Pack, you are asked to:

  • Include tax implications,
  • State importance of the Cheryl Werff summary opinion, and
  • Provide recommendations.

Each research problem is worth 50 points (Total = 100 points)

In addition to these two fact packs, you will be presented with a computational exercise having three distinct requirements embedded in this exercise. This portion of the Week 6 Project is worth 40 points.


Your instructor will share the information for the different scenarios for this assignment. The beginning of the assignment contains an extensive explanation of the project, as well as guidelines that must be followed in completing the project. You are responsible for knowing and following these guidelines. Some of the more significant guidelines include the following.

  • Submit a separate document for each of the three portions of the assignment. They are:
    • Kenny’s Fact Pack
    • Blough’s Fact Pack
    • Computational Exercise
  • Your submissions must be completed in Microsoft Word.
  • You must use a reasonably easy-to-read font, such as Times New Roman or Arial, in at least 12-point font size. Each page must have at least a one-inch margin on all sides and be double spaced.
  • Appropriate citations are required.
  • The tax memorandums must be in traditional tax memorandum format, as outlined in Chapter 2 of your text. The research essay should be in traditional essay format, including a cover page and a citation page.
  • All DeVry University policies are in effect, including the plagiarism policy.
  • Papers are due at the end of Week 6 of the course.
  • General questions about this paper may be discussed in the weekly Q & A discussion topic. If they are specific or substantive in nature, such as questions concerning the analysis of one or more of the materials provided, please e-mail such questions to your instructor.
  • This project is worth 140 points. You will be graded on the overall quality of your submission, including the quality of your analysis and the professionalism of your submission. Details concerning the grading criteria follow.


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