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The research paper format should be
1) Facts-A brief statement of the facts that have a tax effect
2) Issue-The tax questions raised by the facts
3) Conclusion-A brief answer to the question, without any statement as to why.
4) Reasoning: This is “why” your answer is what it is. It is likely the bulk of the paper. Give primary authority for each statement made.
Explanation of Conclusion vs Reasoning: An example
The facts are a car dealer allowed a valued employee to purchase one of his cars for significantly less than it cost the employer.
The “Issue” was: “whether a very large discount offered an employee on a product is income?”
The Conclusion could be as simple as: “Yes” or “Yes, to the extent the selling price is below the employer’s cost”
The conclusion is thus just the answer, without explaining why.
Then in “Reasoning” you would explain why you reached the conclusion you did citing and explaining the rules used, and citing the authoritative source for your answer, such as a IRC section or regulation, Court Decision etc.
Citations can be in the form of footnotes, either on each page or at the end of the paper, or in legal format embedded after the statement being supported.
However, every statement of a rule or law that you use in your paper must be supported and cited to the primary authority from which it is derived. Sources like the textbook or IRS consumer pamphlets while helpful, are not
authority you can cite.
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