Write a tax research memo identifying the Relevant Facts, Issues Identified, Conclusions, and Authorities and Reasoning for the tax problem listed below. Apply at least one relevant court case.

Write clearly and concisely so that the tax memo is no more than three pages. Use the APA style on margins, fonts, grammar, punctuation, writing skills, and spacing. Do not copy and paste the facts as listed below. Include your source in a separate page. You should include only the relevant facts and use your own words whenever possible.

Tax Problem:

Your client, Ray, was overly stressed and quit his job as a corporate executive. Rather than finding a new desk job, Ray decided he would devote his newly found free time to betting on horse races. Ray devoted a significant amount of time to studying the horses and race related information. In fact, he spent more than 60 hours each week on racing activities. Having previously worked as an executive, Ray kept very detailed accounts of his wagers, wins, and losses. In the prior year, Ray reported net winnings of $100,000 on bets of $113,000, thus resulting in a net gambling loss of $13,000 for the year.

Your manager has asked you to prepare a tax research memo indicating how Ray should report his gambling winnings and losses.