Tax Research Memo on Recoverable Fees for Expert Witness Testimony in the U.S. Tax Court

OVERVIEW For this assignment, you will be submitting a tax research memo regarding the scenario detailed below. INSTRUCTIONS The memo should be submitted in the form of a Microsoft Word document, using only the template provided, and labeled as follows: lastname_memoTax Court.doc. Please note the following specifically for this assignment: - The Relevant Facts - Specific Issues - and Conclusions sections of the memo should be thorough but concise. The key portion of the memo will be the Support section, which should be properly supported by appropriate regulation citations (be specific with section, number, paragraph, and subparagraph as applicable). As this is a memo, and not a formal writing assignment, current edition APA format is not required. Furthermore, there is no need to submit a title page or research page. Just substitute “Your Firm” at the top of the memo with your full name. Prepare (in good form) a research memorandum to the file. SCENARIO: Robert Jones has just rendered service for a taxpayer as an expert witness in a case heard by the U. S. Tax Court. The taxpayer is requesting reimbursement for Jones’ fees and for those amounts paid to her attorney in presenting the case. Jones’ billing rate for this type of engagement is $500 per hour, the market rate for such services in his city, plus out- of- pocket expenses (e. g., auto mileage, computer charges). How much of Jones’ fee will the taxpayer recover?