Question

Prepare a defensible strategy for the client by using the six (6) steps in the tax research process.

Create a fact-based argument that you plan to propose to the client as a defense of his / her position with the IRS.

Predict a counter argument that the IRS could use to validate its position. a response to the predicted IRS counter argument. Provide a rationale for the prediction.

Answer 1

The first step in the tax research process is to establish all of the facts and circumstances provided by your client in order to determine which tax laws(s) apply to your client’s fact pattern.  

The second step in the tax research process entails determining all of the tax issues affecting your client’s specific facts and circumstances and any and all mitigating factors

The third step in the tax research process entails identifying the specific authorities to support all of your client’s tax issues while appropriately weighing authorities that may be contrary to your supporting position

The fourth step in the tax research process entails the resolution of your client’s tax issues after identifying, analyzing, and interpreting all of the applicable authorities.

The fifth and final step in the tax research process entails communicating the conclusion to your client. Your client, of course, must ultimately make the final decision concerning what course of action to take, even though the client’s decision is guided by and often dependent upon the conclusions reached by you, the tax professional.  

2)