A research memo you can put in the file, cited to the text.
Type the question and the facts. CitedTax retrieves the governing authority from its corpus of primary law, writes the memo in the issue, facts, authority, analysis, conclusion form, and grades each step by how firmly the text supports it. Nothing is asserted without a citation you can open.
- Cost
- 1 credit ($25)
- You provide
- the question, the facts, the tax years, your working position if you have one, and what you have already considered
- You receive
- a research memo addressed to your firm: issue, facts, authority, analysis, conclusion, with evidence grades
- Turnaround
- about thirty minutes
Credits never expire. A request that fails on our side returns its credits automatically.
Three things to count on.
Primary authority first
The Code, the regulations, published guidance, and the cases, each quoted at the operative sentence. Secondary sources are never cited as authority.
Evidence grades on every step
Verified, confirm, procedural or withheld, the same grades as the review papers, so the reader sees where the memo is firm and where it is not. Each authority carries its weight label, and the cover carries a research record: when the memo was generated, the index vintage, and how many positions were researched, verified and withheld.
Addressed to the firm
Written for a professional reader and placed in the client file; a client-facing summary is one click when you want it.
Does a client's short-term rental qualify for the real estate professional exception?
The memo walks the material participation tests, the seven-day average rental period rule and the grouping election, applies them to the hours the client logged, and concludes with the grade each conclusion earns from the text.
The same engine, eight other doors.
Every finding cited to primary law
Cited reply to an IRS or state notice
First-time abatement or reasonable cause, IRM cited
State-by-state matrix or S corp versus LLC on real figures
Protest a proposed adjustment to Appeals, petition the Tax Court, request a CDP hearing
Streamlined filing or voluntary disclosure, the penalties and the years computed
A private letter ruling request in the format the annual revenue procedure requires
A claim for refund that is timely and complete, every ground stated and cited