The assignment is a Research Tax Memo. Please note that the Memo does NOT have to be 550 words it could be long or short depending on the issue, so don’t stick to the number of words. I will provide you with the resource (Code Section). You can quote from the resource as much as needed. Quotation is better than paraphrasing in this assignment. Please be very clear for the reader.
Tax Research Memo must contain the following sections:
Facts:Discuss facts relevant to the question presented.
Issue:State the specific issues that the memo addresses. Example: can Mike deduct his workers’ meals
Conclusion: There should be one conclusion per issue. Each conclusion should answer the question as briefly as possible, and preferably indicate why the answer is what it is.
Rules:List the rules related to the issue from the resource.
Analysis:The goal of the analysis is for the researcher to provide the reader a clear understanding of the area of law and specific authorities that apply. Typically, an analysis will be organized to discuss the general area(s) of law first (the code section) and then the specific authorities (court cases, revenue rulings) that apply to the research question.
Citation: Here is the link of the website where I got the resource www.intelliconnect.cch.com
The assignment question:
Shaun is a huge college football fan. In the past, he has always bought football tickets on the street from ticket scalpers. This year, he decided to join the university’s ticket program, which requires a $2,000 contribution to the university for the “right” to purchase tickets. Shaun will then pay $400 per season ticket. Shaun understands that the price paid for the season tickets is not tax deductible as a charitable contribution. However, contributions to a university are typically tax deductible.
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1
Current Internal Revenue Code
,
History Notes – SEC. 170, CHARITABLE,
ETC., CONTRIBUTIONS AND GIFTS.—Subsec (l),
T
REATMENT OF
C
ERTAIN
A
MOUNTS
P
AID TO OR FOR THE
B
ENEFIT OF
I
NSTITUTIONS OF
H
IGHER
E
DUCATION
.—
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• 1990, Omnibus Budget Reconciliation Act of 1990 (P.L. 101-508)
P.L. 101-508, §11801(c)(5):
Amended Code Sec. 170 by redesignating subsection (m) as subsection (l).
Effective
11-5-90.
P.L. 101-508, §11821, provides:
(b)
S
AVINGS PROVISION.
—If—
(1) any provision amended or repealed by this part applied to—
(A) any transaction occurring before the date of the enactment of this Act,
(B) any property acquired before such date of enactment, or
(C) any item of income, loss, deduction, or credit taken into account before such date of enactment, and
(2) the treatment of such transaction, property, or item under such provision would (without regard to the amendments made by this
part) affect liability for tax for periods ending after such date of enactment,
nothing in the amendments made by this part shall be construed to affect the treatment of such transaction, property, or item for
purposes of determining liability for tax for periods ending after such date of enactment.
• 1988, Technical and Miscellaneous Revenue Act of 1988 (P.L. 100-647)
P.L. 100-647, §6001(a):
Amended Code Sec. 170 by redesignating subsection (m) as subsection (n) and adding after subsection (l) new subsection (m).
Effective
, generally, for tax years beginning after 12-31-83. See Act Sec. 6001(b)(2), below, for a special rule.
P.L. 100-647, §6001(b)(2), provides:
(2)
W
AIVER OF STATUTE OF LIMITATIONS.
—If on the date of the enactment of this Act (or at any time within 1 year after such date of
enactment) refund or credit of any overpayment of tax resulting from the application of section 170(m) of the 1986 Code (as added by
subsection (a)) is barred by any law or rule of law, refund or credit of such overpayment shall, nevertheless, be made or allowed if claim
therefore is filed before the date 1 year after the date of the enactment of this Act.