Write a memo to the tax file discussing the facts of the tax question.
Juan owns a business that acquires exotic automobiles that are high-tech, state-of-the-art vehicles with unique design features or equipment. The exotic automobiles are not licensed or set up to be used on the road. Rather, the cars are used exclusively for car shows or related promotional photography. With respect to the exotic automobiles, Juan would like to know whether he can take a cost recovery on his Federal income tax return.
Partial list of research aids: Bruce selig, 70 TCM 1125, T.C. Memo. 1995-519
Require:
You will write a memo to the tax file discussing the facts of the tax question, identifying the relevant tax issues, including appropriate citations, and communicating your conclusion and any advice.
The general outline is as follow:
Paragraph 1: Identify the problem
Paragraph 2: Review the sources (code sections of tax law sources). This paragraph is your analysis of the facts and how the law applies.
Paragraph 3: Arrive a solution. State your conclusions, the logic that supports your conclusions and any advice that will be communicated to the client.
It is important that you attach copies of code sections, revenue rulings, RIA analyses etc. that are cited in the discussion or that you used in arriving at the conclusion.