Description
HELLO, PLEASE I NEED YOU TO FOLLOW ALL THE INSTRUCTIONS
Unformatted Attachment Preview
Tax Memorandum A:
Instructions:
This is an individual assignment. The memo should be two pages and students should use the tax
memo template provided. The answer should be a full 2 pages (double spaced, times new roman
12pt., 1-inch margins) Do not repeat the question in the answer. Each memo must include an
explanation of the relevant code sections, regs and/or other relevant controlling authority such as
case law. Don’t just cite the rules or cases, explain them and their application to the specific facts
in the questions. Any memo with a similarity score exceeding 25% on Turnitin will be rejected
subject to the professor’s review and sole discretion. All tax memos are due on Sunday of each
week assigned.
Relevant Facts:
Marcuse Aurelius is the CEO of Latifundium Corporation (LC), a Chapter C Corporation. LC
manufactures agricultural fertilizers for agribusiness consortiums. The primary raw material used
in the fertilizer production is rock phosphate which is extracted from a mine owned by LC a few
miles from the fertilizer processing plant. In 2018, Aurelius purchased, modified, and installed
two new industrial furnaces in the processing plant. The new equipment was placed in service on
April 1, 2028 and was subject to depreciation under IRC Section 167(a)(1). In August 2023,
Conagra offered to purchase one of the furnaces from LC. Aurelius has come to you for advice
regarding the tax implications of a sale by LC of the furnace.
Questions:
1. Under the terms of Section 1221 what is the tax treatment of the gain or loss from the sale of
depreciable trade or business property, or real property used in a C Corporation’s trade or
business? Explain.
2. For tax planning purposes, could Section 1231 change the result? Explain.
Tax Research Memo
Sample Format
Your Firm
Your Town and State
Date
Relevant Facts
Specific Issues
Conclusions
Support
Purchase answer to see full
attachment
