You will need to create a tax memo based on the prompt that I attached. I will provide an example of a tax memo and the one you will create has to be similar format. You will need to use only primary sources for this tax research and properly cite them as the example provided. 

Federal tax research involves a large variety of primary sources of law: the Internal Revenue Code, Treasury regulations, case law, and several types of agency guidance published by the Internal Revenue Service.

Here is a link that will help you access these primary sources: 

https://guides.loc.gov/tax-law/primary-sources#:~:text=Federal%20tax%20research%20involves%20a,by%20the%20Internal%20Revenue%20Service.