I upload files of the assignment of the tax memo will help you more
Mimi’s Grocery Chain of Stores, Inc. (“Mimi’s Grocery Chain of Stores”) is a C corporation. Mimi’s
Grocery Chain of Stores is a calendar year taxpayer. Mimi’s Grocery Chain of Stores operates a chain of
grocery stores. Mimi’s Grocery Chain of Stores is very profitable, especially during the pandemic.
However, senior leadership recognizes that many customers in the areas where they operate have lost
their jobs and/or suffered a loss of income. Mimi’s Grocery Chain of Stores has decided to donate food
to local organizations to assist people who are suffering from food scarcity. The local organizations are
tax exempt organizations and are food banks. The food to be donated is all within the expiry dates of
the food items and consist of fresh fruit and vegetables, canned goods (some canned goods my be
dented cans) and baked goods. All the food to be donated would be edible food.
Mimi’s Grocery Chain of Stores would like to understand the amount of the income tax deduction that
may be allowed for these donations (in tax parlance these are often referred to as charitable
contributions). Mimi’s Grocery Chain of Stores has not provided the basis and fair market value of the
goods so you may want to explain the difference where the basis is $100 and FMV is $110 vs basis is
$100 and FMV is $210. You can safely assume the donations for the year will exceed $500,000.
When researching you may want to consider the following (and please note this is not an exhaustive list
just a guide to help you get started):
IRC §170(e)(3)
Regs. Sec. §1.170-4A
Lucky Stores, Inc. 105 T.C. 420 (1995)
Your responsibility:
Prepare a tax research memo addressing the question that has been raised. Please note that if the tax
memo is not in the required format and/or contains very little analysis you will receive a zero (0) for the
assignment. All good faith efforts are capable of receiving a minimum of 60% but less than a good faith
effort will be awarded zero points.
You will need to support your conclusion using primary sources of tax law. Your textbook is NOT
primary authority nor are IRS Publications
You must use proper citation form in your memo (see Chapter 2 for help with citation form). The form
for this communication should be professional and in the form of a tax research memo (example posted
on Blackboard and a similar example in your textbook). Do yourself a favor and look at the grading
rubric before you submit.
This memo should be whatever length you feel is appropriate to resolve the issues. We do NOT use a
bibliography or list of references in a tax research memo. You will see that citations are within the text
of the document in the example. Once a court case has been cited in full, it can be referred to using
simply the name in italics
You are required to INDIVIDUALLY prepare this document. Please upload your memo to Blackboard
before the due date and time. TurnitIn will be used to check for plagiarism.
The grading rubric for Tax memos is posted in Blackboard. For this assignment, points are distributed as
follows:
Aspects of the memo Points
Content – facts and issue(s) 16
Content – analysis 30
Content – conclusion 14
Organization 8
Audience 8
Style 8
Mechanics 8
Referencing 8
Total 100
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