
Communicating Research Results
File Memorandum
– Organize fact, issues and conclusions
– Facilitate review of activities by supervisors or colleagues
– Allow for subsequent examination
Initial determination is likely to be incomplete
– Taxpayers see things from just their side
– Taxpayers not trained in law
– Not all statutes of facts are clear
– Memories may not be clear
How to Communicate Tax Research Results
Memorandum
Address
Relevant Facts
Issues
Conclusions
Support
Actions to take
Evaluating Sources of Law
-regulations are seldom found invalid
– revenue rulings and revenue procedures are modified
– higher level courts have higher weight in sayings
– Bound by rules within tax and court district
– 2nd, 9th, Federal Circuits are weighted more
– older cases are worth less unless they are supreme court cases
– tax treatises and journal articles reveal current issues
– IRS agents only bound by code, courts and govt while practitioners – clients
– court decisions are not predictable
Client Letters
Most common form of communication is phone call
Letter gets rid of many risks of calls
Should not exceed 2 pages
Only go over highlights or process
Answers best gone over in person
– Salutation/general conclusion
– Summary of results
– Objective of report
– Statement of facts and disclaimer
– Summer of sources
– Implications of results
– Assumptions and/or limitations
– Closing thoughts and suggest follow up meeting
– Attachments
Effective Guidelines
– Main points in first paragraph
– State a purpose and stick to it
– Avoid filler language
– Avoid clichés or filler jargon that lacks substance
– Follow 10-80-10 rule
- 10% intro, 80% body, 10% conclusion
– Be willing to revise
– Spell names right and use titles
– Practice writing and proof reading
Comprehensive Illustration of Client File
File includes:
– Client letter
– Client Memo
– Engagement letter
– Billing and collection history
– Relevant research
– Links to important analyses
Oral Presentations of Research Results
– General preparation
- Why me?
- What do they want?
- What is their attitude?
- What should I stay away?
- What do they already know?
- Who is the audience?
– Focus on conclusions and main points
– Be brief and concise leaving details for Q&A
– Use visual aids effectively
- To convey difficult ideas text doesn’t explain
- Save time through consolidation
- Create interest
- Emphasize a point
- Organization
- Introduce something to lighten the mood
- Leave an idea in viewer’s mind
- Slides should focus on pictures
- Use a 6 by 6 rule on slides
- Simple font
- Professional background music
- 3 minutes of speech for each slide
- Have back up files and sources for presentation
– Have your own equipment
– Be close to the audience
– Eliminate distraction
– Use tones
– Don’t mind silences
– Do not read from slides or outline
– Have plan B ready if needed
– Avoid cliché jokes