Here is the assignment. I would appreciate the help.
Attached is also the assignment for better viewing purposes. Please use primary sources such as the IRS and please list your sources.
Tax Research Memorandum
No tax professional can function effectively without adequate tax research skills. This project is designed to be similar to a simple tax research assignment a new professional might encounter in a CPA firm or corporate tax department
As an anti-plagiarism measure (this has been an issue in past classes), the electronic copies of your memorandums may be processed through the Safe Assignment function to check for inappropriate “borrowing” of text and concepts
1. John and Susan Gray have decided to adopt a child. They have agreed to pay for the medical bills associated with pre-natal care, delivery costs, post-natal care of the mother and child (total estimated at $8,000), attorney fees ($7,000), and to make a $5,000 contribution to the religious organization through which the adoption is being effected. The child will be transferred to the Gray’s the day after birth although the adoption will not be completed for approximately six months due to the need to complete and file legal documents and releases, meet state law requirements, and obtain court approvals.
The issues I am trying to solve or the queries that I have to solve are
1. Can the couple deduct or claim some kind of credit for the adoption expenses?
2. If so, is there a limit to this deduction or credit?
3. Is there a certain time period the deduction or credit must be taken?
Attached is a research memorandum template (with certain explanations) you are to use in preparing your actual research memorandum (Phase 2).
The project will be reviewed and scored based upon several criteria, including but not limited to: (a) how thorough and accurate your research is, (b) appropriate and complete citations/documentation of the applicable law (primary sources) as well as any other support used in arriving at your conclusions (secondary sources), (c) neatness and completeness of the memorandum you submit, and (d) the clarity and succinctness with which you communicate your conclusions.
As stated above, your focus should be on “primary sources” such as the Code, regulations IRS rulings and court cases. Secondary sources, such as the CCH Explanations, can be used as background and/or support for the conclusions you derive from examining the primary sources. For purposes of this project, IRS Publications are considered secondary sources although CCH may list such publications as primary sources. DO NOT prepare a paper that contains little more than a cut and paste of CCH explanations and/or excerpts from IRS publications – these items are another persons’ interpretations/conclusions of the tax law, not yours.
Your score will also be influenced by how closely you follow these specified instructions in all material aspects. As CPAs/tax practitioners, it is essential that you learn to comply with certain specified rules and regulations. Thus, how closely you adhere to the specified parameters of this project is part of the scoring process. This project is worth up to sixty (60) points
TO: Hy Incümm – Tax Partner in Charge
FROM: Ima Pyoopul – Assistant Tax Specialist
DATE: April 22, 2014
SUBJECT: Research Project – Problem Number X-YY
In this section of the memorandum a student should essentially copy the facts (text) of the case problem you have selected from the posted list (to the extent your case specifies a question(s), do not include that language here but below in the Queries section). You must not make any material modifications or embellishments to the problem as provided.
In this section of the memorandum a student would delineate in sufficient detail the tax question or questions identified in the case facts. This section pertains to Phase 1 of the project and is your first significant challenge – to identify what the major tax issue or issues is/are in your case. While your case may already contain a general question or statement, a student generally must augment and/or restatement of the question(s) in greater detail. Note the due date of Phase 1 as specified in the course syllabus – students must submit the tax issue(s)/question(s) they have identified via the BlackBoard Message Function – see above in Appendix A for more information.
This section of the memorandum sets forth, in concise summary form, the conclusions derived from the arguments and authorities set out below. There should not be any “intuitive leaps” – all conclusions should flow from the cited research.
ARGUMENTS AND AUTHORITIES:
This section of the memorandum contains a student’s technical analysis of the issue(s) at hand along with appropriate supporting citations (proper citation format is important). This analysis should include all pertinent and relevant primary sources (e.g. IRC, Revenue Rulings, Treasury Regulations, court cases, etc.) as well as any secondary sources used to support the analysis (e.g. CCH explanation). Emphasis must be placed on primary sources – do not simply cut and paste a CCH explanation or IRS Publication and call it a day. Students should generally list at least two (2) primary sources in completing this project. Please review the sample research memorandums posted to BlackBoard for more information as to what this section should contain.