Tax Research Memo

REQUIREMENT

Each student must individually complete a tax research project memo. Students should choose one of the three topics below. The memo should be typed and in the format provided below (labeled Appendix A-6). Students should use RIA Checkpoint, available through the PSU library to conduct the research. It will be graded on accurately and insightfully analyzing the given facts with proper tax law and citation, as well as presentation (clarity and conciseness of the writing). See the grading rubric below for additional details. Note that only primary sources should be cited. Primary sources include the Internal Revenue Code (IRC), Revenue Rulings, and court cases, but do not include anything from the IRS. The Appendix posted on D2L provides greater details.

The research memo must be submitted on to the dropbox on D2L in PDF form prior to the due date. Outside of extenuating circumstances, late projects will have 5% deducted from the grade for each day beyond the due date, up to a maximum of 20% deduction. Projects will not be accepted after February 19, at which point solutions will be posted.

Choose one of the three topics below:

Topic 2
Lynette, a famous basketball player, is considering the possibility of transferring the sole right to use her name to promote basketball shoes produced and sold by the NIK Corporation. NIK will pay $2 million to obtain the right to use Lynette’s name for the next 40 years. NIK may use the name on the shoes as a part of any of the company’s advertisements for basketball shoes. If Lynette sings the contract and receives the $2 million, will she have to recognize capital gain or ordinary income?

Identify Facts and Issues

Clearly and concisely identify the relevant facts and issues from the facts provided. Identifies most of the relevant facts and issues from the facts provided. Does not Clearly identify the relevant facts and issues from the facts provided.


Context, Purpose, and Audience

Demonstrates a thorough and creative understanding of context, purpose, and audience. Demonstrates adequate consideration of context, purpose, and audience. Does not demonstrate appropriate attention to context, purpose, or the intended audience.


Identify and Use


Relevant Sources of Tax Law Thoroughly identifies high-quality, credible, and relevant sources of tax law that apply to the facts provided and demonstrates a skillful and thorough use of the sources to enhance the communication. Sources are correctly cited. Identifies relevant sources of tax law that apply to the facts provided and demonstrates a consistent use and understanding of the sources to support the communication. Sources are generally cited correctly. Does not identify relevant sources of tax law that apply to the facts provided and or appropriately or effectively use them to support the communication. Sources may not be cited correctly.
Analysis Correctly and concisely analyzes how the relevant sections of law apply to the facts provided. Adequately analyzes how the relevant sections of law apply to the facts provided. Does not adequately analyze how the relevant sections of law apply to the facts provided.


Propose Reasoned Solution

Thoroughly and accurately summarizes how the relevant laws apply to the facts provided and explains the outcome as it relates to the tax treatment. Adequately summarizes how the relevant laws apply to the facts provided and explains the outcome as it relates to the tax treatment. Does not adequately analyze how the relevant laws apply to the facts provided and explains the outcome as it relates to the tax treatment.

Manner of Presentation

Message is skillfully delivered with a clear, concise and persuasive authority. Very professional and free of grammatical and typographical errors. Message is delivered in a clear and concise manner. Demonstrates consistent use of professional communication conventions. Generally free of grammatical and typographical errors. Does not present the message in a clear or appropriate manner. May contain grammatical and typographical errors.

Summarize and  Conclude


Information A central message is summarized in a high quality conclusion that provides a recommendation. The message is clearly and concisely written, and provides a logical summary based on the laws, analysis, and proposed solution. A central message is summarized in a quality conclusion that provides a recommendation. The message is well written, and provides a logical summary based on the laws, analysis, and proposed solution. Conclusion may not provide a central message is summarized in a quality conclusion that provides a
recommendation. The message may not be clear or concise, and may not provide a logical summary based on the laws, analysis, and proposed solution.

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