Hello, Can someone please help me with this memo?

Can someone please help me with this memo?
Please see attached file. Thanks
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. 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.

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