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Please draft an “Internal Research Memo” (See Exhibit 2-9) for R.S. Clark, TC Memo. 2021-114. 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. Graduate students should cite at least 6 references. Any quotes should be minimal and included within quotation marks.
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