Upload a document that provides the following information.
1) Give a simple, nontechnical 1 sentence answer to the question posed (this is not a writing assessment, focus on research).
2) What is (are) the Code section(s) at issue?
3) Are any Treasury Regulations relevant?
4) List the case authority on which you relied to arrive at your answer (please provide the name of any case, not just a citation).
5) Provide a step-by-step description of how you arrived at your answer and located the primary sources that you used to support it (include a discussion of the case law or Ruling authority on which you relied).
Sample formats for this assignment are in the Conducting Tax Research materials. However, you may use whatever format you wish as long as you address the five items noted.