The code section should relate to partnership distributions, transfers of interests, sales, or terminations.
Locate the Internal Revenue Code Section that governs the topic of your choice.
Search a tax research database (CCH, BNA, etc.) for a court case involving your topic and code section of choice.
Read the court case and familiarize yourself with the parties involved, facts surrounding case, etc.
Synthesize your court case into a tax memo.
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