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Please draft an “internal Research Memo” (See Exhibit 2-9) for Estate of Richard R. Simplot,87 AFTR2d 2001-2165, 5/14/01. 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.
https://caselaw.findlaw.com/court/us-9th-circuit/1…
this is the case
