You are to prepare a tax research memo regarding the following fact pattern. Your memo should include four sections: Facts, Issues, Conclusion, and Discussion. A sample research memo is can be found at www2.gsu.edu/~accerl/. Your memo should be 1-2 pages, single spaced. You will need to cite primary authority (in APA FORMAT) in your memo including at least one court case. All sources should be cited.

Facts:

Your client, a German named Werner, presented you with the following facts. Werner visited his brother Klaus, who immigrated to the United States eight years ago and has been living in Washington, DC. At the time, Werner was under contract to a German soccer team and was expected to return to the team to begin play for the fall 2014 season. Werner's brother Klaus had fallen in love with American football and was a huge Washington Redskins fan. The Redskins had recently lost their regular kicker to an injury. They picked up a new kicker on waivers, but he was a disappointment. Knowing of Werner's kicking ability, Klaus was convinced that Werner could help the Redskins. Klaus took Werner to a Redskins workout and introduced him to the kicking coach. As a result, Werner was given a tryout by the Redskins, who were desperate for a good kicker. Werner's performance was far superior to others at the tryout, and the Redskins offer him the job. Werner was reluctant to accept the offer because he had planned to return to Germany in a few weeks to continue his soccer career. Considerable encouragement from Klaus and the Redskins organization seemed to be in vain until the Redskins, at Klaus's suggestion, offered Werner a $100,000 bonus. At this point, Werner overcame his reluctance and signed a contract, which Klaus co-signed as a witness and interpreter. Economically speaking, the regular salary offered by the Redskins was considerably more attractive than his salary as a soccer player in Germany. Grateful to his brother for assisting as an interpreter and negotiator, and for encouraging him to stay, Werner instructed the Redskins to pay $15,000 of the negotiated bonus directly to Klaus. Klaus reported the $15,000 as other income on his 2014 income tax return and paid the appropriate tax. After examining Werner's 2014 tax return, the IRS made a deficiency assessment claiming that the $15,000 paid to Klaus constituted income to Werner and should thus be included in his income.

Your manager has asked you to prepare a tax research memo indicating if the $15,000 should be included in taxable income for Werner.