Have to write a tax memo. I am attaching an example from different case, I want

Have to write a tax memo. I am attaching an example from different case, I want it written like that. You will also have to use platforms like RIA or CCH to do your tax research based on the following case. Let me know if you do not have access to such databases. You will have to use primary sources in tax to conduct the analysis and conclusion.
The PDF is the example on how it should exactly look like.
The word doc is the instructions of the assignment.