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Attached is your second Tax Research Assignment. Your grade on the project will be based on the effectiveness of your tax research as well as the quality of your communication to your client of the results of your research. Spelling, punctuation, grammar, and organization of your memorandum communicating your results will factor into your grade, as will proper citation and description of any authorities your research has identified. Note that research conclusions should be supported by reference to and discussion of primary authorities. See http://www.irs.gov/irm/part4/irm_04-010-007.html for the citation format for statutory, administrative, and judicial primary authorities. You should submit your memorandum in your assignment folder in pdf format. Please see the Sample Tax Research Assignment with the Sample Tax Research Memo as an exemplar of how to communicate tax research findings. These documents can be found under Tax Research in your Course Table of Contents. In addition, please review the sample Tax Research Problem and Solution and the Tax Research Guidance documents for tips on finding relevant primary authorities to support your research memo conclusions.
Doctor Bones prescribed physical therapy in a pool to treat Jack Borden’s broken back. In response to this advice (and for no other reason), Jack built a swimming pool in his backyard and strictly limited use of the pool to physical therapy. Jack paid $25,000 to build the pool. Jack consults you for advice concerning whether this amount or any portion of the amount would qualify as a deductible medical expense on his federal income tax return. Research the tax law and write Jack a brief memo of no more than two pages, in which you communicate the results of your research. Use the format for communicating research findings modeled in the Sample Tax Research Assignment with the Sample Tax Research Memo, which can be found under Tax Research in the Course Table of Contents. Identify relevant statutory, regulatory, and judicial authorities and discuss how these authorities affect your conclusion concerning the deductibility of the pool construction costs as a medical expense on Jack’s federal income tax return.