WRITING ASSIGNMENT GUIDELINES – Chapter 4
Assume that you are a staff accountant working in the tax department of a Big 4 accounting firm. Your
client approaches you directly for advice. Prepare a detailed Client Letter analyzing a specific tax
scenario using Primary Federal Tax Law sources only. Please write a client letter based on:
Research Problem #1 (Client Letter to Tranquility, Inc., Re: Preneed Contracts)
>>> Chapter 4, Page 46
• Client letters are short – no need to include separate headings. Please refer to Chapter 2 (page 2-
28) for an example of a client letter.
o One letter addressed to your client is sufficient.
• The letter should be at least 1 page but no more than 2 pages (single-spaced).
• Your letter should include separate paragraphs with a discussion about (1) the relevant facts, (2)
tax issue(s) / write out the research question, (3) citation of relevant code section(s) and at least
one court case, (4) analysis (apply relevant tax laws to the facts), and (5) your conclusion.
o To provide a solution to your client’s issue, you need to be able to identify the research
• Provide clear and logical arguments for your conclusion. Your arguments will be supported by
the relevant IRC and the court case.
• Be sure to read the relevant chapter before completing the assignment. The textbook chapter
cites relevant code sections that you may want to look up and mention in your client letter.
o Find at least one court case with similar circumstances and discuss the case in your
letter to support your conclusion. Explain how the facts in the selected court case are
similar to the relevant facts of your client (i.e., the court case needs to discuss the same
tax issue as your clients’ tax matter). The court case you find must involve the IRS /
Commissioner and/or United States as one of the parties arguing a tax issue relevant to
o Many court cases are appealed and are heard by the appellate courts. Please be sure to
find the latest version of the court case.
o There is no specific requirement for citing code sections and court cases. Your citations
may look like this: Internal Revenue Code section 61(a) or A. J. Miller vs. U.S.
• No need to include Reference page. You need to include the citation of the primary tax law
source within the letter.
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Tax research involves the following procedures:
1. Identify the tax issue
2. Discuss relevant facts and transactions
3. Identify appropriate tax law sources – cite primary sources only; include at least one court case
examining similar tax research question
4. Provide your conclusions and support your analysis with clear and logical arguments
5. Discuss any assumptions made in arriving at the solution
Tax Research Resources:
• Your books
come with instructions and an access code to RIA Checkpoint. RIA is used by many public
Other web sites that may provide useful information are:
• Cornell University Law School web site has the IRC:
• IRS web site: www.irs.gov
• Court opinions: www.law.justia.com
• The writing assignments are individual projects. Collaboration with others (i.e., anyone
including family, friends, students etc.) will result in a grade of zero.
• The penalty for late submissions is a deduction equal to 20% of assignment’s earned score per
day counting weekdays and weekends.
• You will be graded on the thoughtfulness of your discussion as well as on the writing quality.
• You will be graded on the persuasiveness of your arguments and whether your arguments are
well-supported by court cases and IRCs.
• The grading rubric is posted on Cougar Courses.
• Proofread your paper for spelling and grammatical errors, and check whether the paper reads
well. Consult a dictionary and/or a style manual for spelling and grammar problems.
• Avoid one-sentence paragraphs. By definition, a paragraph is a group of sentences constructed
around a central topic.
• Avoid contractions. Business reports (client letter) should not use contractions. For example,
use “should not” instead of “shouldn’t.”
• Try to use the active voice rather than the passive voice. For example, instead of writing “This
case was decided by the Tax Court,” write, “The Tax Court decided this case.” Papers written
in the active voice read easier, and using the active voice also conserves words.
• Nouns and their modifying pronouns must agree. An example of incorrect grammar: “The
Supreme Court ruled in favor of the government. They rejected the argument of the taxpayer.”
“Court” is a singular noun while “they” is a plural pronoun.
WRITING ASSIGNMENT GUIDELINES – Chapter 4