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ASSIGNMENT Write a memorandum to your client Dr. Green addressing each of the issues listed below. The memorandum should be no less than one page and...
ASSIGNMENTWrite a memorandum to your client Dr. Green addressing each of the issues listed below. The memorandum should be no less than one page and no more than three pages in length. APPLICABLE LAW Use the typical tax primary and secondary resources to include statutes, regulations, IRS guidance, and court decisions to formulate your advice regarding each of the issues listed below:ISSUES1. Dr. Green is a practicing physician in Chicago who, as an avid blackjack and slot machine player, travels to Las Vegas every other weekend to gamble. He would like to know what criteria are used to determine whether his gambling activities constitute a trade or business for federal income tax purposes and whether or not you think his gambling activities qualify for trade or business status.2. If Dr. Green's gambling activities do not qualify as a trade or business, can he deduct his gambling-related travel and lodging expenses against his gambling winnings?3. Assume Dr. Green's wife, Mrs. Green, gambles to the same extent that Dr. Green gambles. Assume that the Greens file a joint tax return. If Mrs. Green has a large net gambling gain for the year and Dr. Green has a large net gambling loss, can they combine their gambling transactions and use his loss to offset her winnings?FORMATUse the following format and specifics:MEMORANDUMDr. GreenFROM: Your NameToday’s DateTax Memo #1/Gambling ActivitiesFor each issue, begin by restating the issue. Then, explain and discuss the tax rules that apply to the issue, which you gleaned from your tax research. Then, conclude with a definitive answer to the issue, supported by citations to the sources used. So, for each issue, you should:State the issue, Explain and discuss the applicable law (IRC sections, regulations, court decision, etc.), and Present your answer in the form of a concluding paragraph that refers to specific language from the IRC sections, regulations, court decisions, and other sources (if applicable) to support the conclusion.CITATIONSCitations are required. You must provide cites whenever you refer to the sources of tax law used in this memorandum. You may cite your sources in numbered footnotes, numbered endnotes, or in parentheses immediately after the sentence mentioning the cited source.
