Write a tax research memo identifying the Relevant Facts, Issues Identified, Conclusions, and Authorities and Reasoning for the tax problem listed below. The underlined headings in the prior sentence are defined on page 149 of the text. Apply at least one relevant court case.
Write clearly and concisely so that the tax memo is no more than three pages. Use the APA style on margins, fonts, grammar, punctuation, writing skills, and spacing. Do not copy and paste the facts as listed below. You should include only the relevant facts and use your own words whenever possible
Your client, a U.S citizen named Werner who only speaks German and lives in Texas, presented you with the following facts.
Werner visited his brother Klaus in Washington, DC. At the time, Werner was under contract to a German soccer team and was expected to return to the team to begin play for the fall 2013 season. Werner’s brother Klaus was in love with American football and was a huge Washington Redskins fan. The Redskins had recently lost their regular kicker to an injury. They picked up a new kicker on waivers, but he was a disappointment. Knowing of Werner’s kicking ability; Klaus was convinced that Werner could help the Redskins. Klaus, an amateur American football player himself, trained Werner in kicking field goals. Klaus took Werner to a Redskins workout and introduced him to the kicking coach. As a result, Werner was given a tryout by the Redskins, who were desperate for a good kicker. Werner’s performance was far superior to others at the tryout, and the Redskins offered him the job. Werner was reluctant to accept the offer because he had planned to return to Germany in a few weeks to continue his soccer career. Considerable encouragement from Klaus and the Redskins organization seemed to be in vain until the Redskins, at Klaus’s suggestion, offered Werner a $100,000 bonus. At this point, Werner overcame his reluctance and signed a contract, which Klaus co-signed as a witness and interpreter. Economically speaking, the regular salary offered by the Redskins was considerably more attractive than his salary as a soccer player in Germany. Grateful to his brother for assisting as an interpreter and negotiator, and for encouraging him to stay, Werner instructed the Redskins to pay $15,000 of the negotiated bonus directly to Klaus. Klaus reported the $15,000 as other income on his 2013 income tax return and paid the appropriate tax. After examining Werner’s 2013 tax return, the IRS made a deficiency assessment claiming that the $15,000 paid to Klaus constituted income to Werner and should thus be included in his income.
Your manager has asked you to prepare a tax research memo indicating how the $15,000 should be treated for tax purposes for Werner.