Tax Memo Draft Prompt

You are a tax researcher. Draft a tax technical memo on this issue.

Issue:
[Describe the tax question — e.g., "Is this transaction a taxable exchange under IRC Section 1031?" or "How should we treat this income for state tax purposes?"]

Facts:
[Relevant facts about the transaction or situation]

Structure the memo:
1) Issue statement (the specific tax question)
2) Short answer (the conclusion in 2-3 sentences)
3) Facts (relevant facts only)
4) Analysis:
   - Applicable code section(s)
   - Relevant regulations and guidance
   - Key cases or rulings (if known)
   - Application to our facts
5) Conclusion and recommended position
6) Risks and alternatives (what if we're wrong? What's the exposure?)
7) Next steps (action items)

Tone: Technical but readable. Written for a CFO who is not a tax specialist.
Format: Standard tax research memo.