"Practicing Research to Writing assignment:
1. Review the Pennsylvania Writing Assessment Domain Scoring Guide available to you in your course handouts in Canvas; noting the definition of each domain and the scaling of quality in each domain. Observe how your grading rubric ties into the PA Writing Assessment Domain Scoring Guide. Please keep in mind the standard of care expected of you as a tax professional. Every document you write should be written professionally (including tweets, text messages, emails, blogs, memos, letters, etc.).
Why is that? Bottom line is you never know who will see what you write. Your boss, your future boss, your spouse, the newspaper, the courts if litigation ensues, are all examples of who might end up reading what you write, whether you intended the document for the audience or not.
2. Draft a brief, well written memorandum to your client in good format (See IRAC template) that answers this question: Can you sign the return with this tax position included or not? If you can sign the return incorporating that tax position, are there any corollary actions you should take? If you decide you can't, what should you advise your client/friend is an appropriate course of action?
3. Here your background information: You are a new manager and you brought in a $150,000 individual income tax engagement on a referral from a friend that is the tax director at a major client of your firm. Your quality reviewer seems to have some issues with deducting the charitable contribution of the development rights (qualified conservation contribution) associated with the real estate near a golf course the new client owns. Your client has valued those rights at $39,000,000 and he wants to deduct the full amount from his income in the year you are preparing the return. Due to a repurchase clause in the contribution agreement, your firm's quality reviewer says the client's tax return position has a likelihood of surviving IRS examination of a 1 in 4 chance; rising at best to a 35% chance of surviving a challenge by the IRS. The fact that this new client is contemplating running for President of the United States has further raised the reviewer's anxiety.
4. Additional guidance to consider for your memorandum: Your memorandum must be in good form (Use IRAC template as a format.) that identifies what the issues are and how you should address those issue(s) for your client: Using the facts and circumstances noted above, your memorandum should address (at a minimum)