Please see attached for my comments.
Remember, you are writing a memo to advise your client. Tell them what they should do. Use case law, statutes, acts, etc. to make your point. Use RIA Checkpoint to find the relevant law.
From the assignment: Prepare a tax memorandum for use in advising your client. State the issue(s) to be resolved and make sure to identify the specific authorities (code, statutes, case law etc.) that address your client’s tax issues. Make sure to weigh authorities both for and against your client’s position.
Be sure to provide an analysis of why the code applies. To quote Professor Weismann, “Be specific in your analysis. Don’t leave it to the reader to figure this out. Make your best case!”
Develop the support section using specific code/law that applies to the specific situation. You should be using RIA Checkpoint to find the appropriate code/law that applies to the case.
Specific Issues need to be in question format.
Memo 1 is a very good start but the support section needs more development. How does the law apply to your client’s situation. Is there uniformity of application between different states? A client recommendation is not a debate. What should your client do?
As for memo 2 it is clear that you did not do the research or answer the questions.
Tax memo A-2 are the two casses
tax memo format is attached too
and Tax Research memo Draft is the one needs to be update it with all the notes above for correction
make sure to cited more sides besides the one is already there.
if more information is needed contact me
