1. Subject: Capital Gains and Losses
2. Internal Revenue Code Section: I.R.C. § 1222
3. Choose any case involving I.R.C. § 1222 or
use Court Case: LITTLE v. COMMISSIONER OF INTERNAL REVENUE – https://caselaw.findlaw.com/us-9th-circuit/1279445.html
4. Read the court case and familiarize yourself with the parties involved, facts surrounding case, etc.
5. Synthesize the court case into a tax memo using the format from the attached example.
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