Draft an “Internal Research Memo”  for https://casetext.com/case/champions-retreat-golf-founders-llc-v-commr-of-internal-revenue

Draft an “Internal Research Memo”  for

https://casetext.com/case/champions-retreat-golf-founders-llc-v-commr-of-internal-revenue

You should cite at least 3 good form references. The references might include Internal Revenue Code sections, Treasury Regulations, IRS pronouncements, and other court cases. Please limit your memo to 700 words or less.

Complete your brief in this Google Doc and submit the URL to Canvas.

Turnitin will check your work for originality.  Any quotes should be minimal and included within quotation marks.