On behalf of the estate and the heirs of the estate, she has consulted your CPA firm for advice on
the income taxation of this transaction. Your firm’s position is that the estate owes no tax on this
transaction, but do discuss the arguments against as well as for this position
This is to be an “official” opinion letter that could be given to the IRS in support of your position
in the event that Bob’s estate is later audited. Be certain to include quotations from the
authorities, as needed, with proper citations (first case reference, full, proper citation (see the
chapter on research in the text) with later references also properly prepared (see the use of
citations by the judges in the cases, and the text)).
The maximum page length is four pages, the minimum is three, and your discussion of
Crane and Tufts should not exceed one. This does not include the statement of the issues
(put that on the first, separate, page) and the research trail (put that on separate pages after
the text of your research). Also, do not include a summary of the facts as you already did
that in the first memo. Use the statement of the issues as I suggested in class today.
It is to be Single-sided, single-spaced, 12 pitch, Times New Roman font, with 1 inch
margins on all sides.
