README.md

# tax-research-memo-drafter

Draft a U.S. federal tax research memo for a single client issue, in the FIRAC structure (Facts / Issue / Rule and authorities / Analysis / Conclusion) that CPAs, EAs, and tax attorneys use to document return positions, planning recommendations, and IRS-controversy support.

## When to use

A preparer, controversy specialist, planning advisor, or tax attorney has:

- a client fact pattern,
- a specific tax question (federal, with optional state overlay),
- partial or full authority research already in hand, **and**
- needs a structured memo that ranks authorities correctly, states a reliability conclusion, and flags whether disclosure (Form 8275 / 8275-R) is warranted.

The skill does **not** give tax advice. It produces a DRAFT memo for licensed-preparer review and sign-off.

## What it produces

- Numbered Facts (Confirmed / Assumed / Unknown tagged)
- Issue(s) framed as yes/no or "is X treated as Y" questions
- Authorities ranked by weight (statute → regulations → revenue rulings → revenue procedures → IRS guidance → case law → secondary)
- Analysis applying each authority to the facts
- Conclusion with a reliability rating (Will / Should / More Likely Than Not / Substantial Authority / Reasonable Basis / Not Sustainable)
- Penalty and disclosure flag (§6662 substantial-understatement / preparer §6694 / disclosure on Form 8275 or 8275-R)
- Open questions and next-step research checklist
- DRAFT label and required licensed-preparer sign-off line

## Inputs the agent will ask for

One question at a time:

1. Tax year(s) and entity type (individual, C-corp, S-corp, partnership, trust, exempt org)
2. Jurisdiction scope (federal only, or federal + named state)
3. Transaction or issue summary
4. Specific question(s) to be answered
5. Client's tentative position (if any)
6. Authorities the user has already located (with citation)
7. Materiality (dollar amount at stake) and audit/controversy posture
8. Purpose of memo (return position, planning, controversy support, opinion letter)

## Feedback & Contributions

Found a gap or have a suggestion? [Open an issue or PR](https://github.com/archlab-space/Open-Skill-Hub/issues) — improvements are welcome.