You have just transferred to the Tax Dept of a well known, prestigious accounting firm and right after the breakfast reception in your honor (keep dreaming), the partner-in-charge kindly requests that you come to his office to accept your first research project.

Upon your arrival in his plush and somewhat intimidating cavernous office, and with all the earlier niceties aside, he starts spitting out various facts and expletives, and you’re able to scratch down some notes, which include:

· His nephew, the kid, was accepted in a university graduate MS in taxation program

· The kid received a scholarship or tuition waiver, so the program is tuition free, which he cannot fathom the kid really deserves

· The kid will be employed to teach undergrad basic accounting at the university

· He hates the kid and the kid’s mother, his sister-in-law, who he says, can’t cook, is ugly and mean.

He then tells you to prepare a formal tax opinion memo addressed to his nephew, Mousy Goofblinder and to be really careful because he doesn’t want the firm to be sued by Mousy’s mother.

Right before he leaves, he tells you to ask his secretary for any details you might need and that the only question he needs you to address is whether the deal the kid has will be subject gross income for US federal income tax purposes. He then mutters something about you better cite the correct Internal Revenue Code section in your answer or you’re going back to working at McDonald’s.

His secretary tells you that you must write Mousy a clear, really well written, grammatically correct, straightforward letter that cites, along with any other pertinent sources, the Internal Revenue Code section(s) that is/are most relevant to the issue. KISS. She also tells you to keep the letter to 2 pages, maximum, as the senior partner never reads anything longer than that without falling asleep and that you should use the format provided in your text (e.g., relevant facts, issue, conclusion, discussion/citations).