Communicating Research Results

1
Communicating Research Results

• Aspects of tax research communication
• Communications and the tax professional
• The file memo
• Evaluating the sources of law
• Client letters
• Oral presentations of research results

2
Communications and the Tax Professional

• Audience
• Supervisor
• Client
• Other
• Form
• Telephone call
• Informal discussion in person
• E-mail
• Letter
• For tax professional
• Tax knowledgeable/tax limited client
• Memo

3
Technical Tax Communications
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The File Memo

• The memo is for the researchers benefit
• Purpose
• Organize facts, issues, and conclusions
• Facilitate technical review by supervisor or
  colleague
• Allow for subsequent examination of research issue

5
The File Memo Format and Content

• Facts
• Brief summary of relevant facts and issues
• Issues
• A list of tax issues being researched
• Conclusions
• Quickly determine whether each issue is pro or
  con for taxpayer

6
The File Memo Format and Content

• Support
• Detailed review and evaluation of controlling
  laws
• Full citations
• Strengths and weaknesses are developed
• Actions to be taken
• Recommendations for subsequent actions for client
• Other strategies for tax positions

7
The File Memo Facts

• Taxpayer will not always provide all relevant
  facts
• Taxpayer may forget (potentially detrimental)
  facts
• Taxpayer does not always know which documents are
  important
• Must rely on taxpayers memory
• Loss of records/witnesses
• The researcher must use experience to obtain all
  the relevant facts from the taxpayer

8
The File Memo Links and Attachments

• Only most important documents, such as
• Case briefs
• Highlighted copies of primary sources of law
• Highlighted copies of explanatory material
• Related in-house memos
• Journal articles

9
Evaluating Sources of Tax Law

• Regulations seldom held to be invalid
• Revenue Rulings and Revenue Procedures
  frequently modified or held invalid
• Higher court decisions receive additional
  precedential weight
• District and Circuit Court opinions directly
  affect only taxpayers in those jurisdictions

10
Evaluating Sources of Tax Law

• A well-written court case opinion contains a
  wealth of information on tax issues
• Identifies pertinent tax law
• States competing interpretations of the law
• Identifies critical facts and issues
• Often includes lengthy concurring and dissenting
  opinions

11
Evaluating the Sources of Law

• Important Circuits
• 2nd Circuit (includes New York)
• Authoritative in traditional sense
• 9th Circuit (includes California)
• First to introduce innovative or unusual
  interpretations
• Federal Circuit
• Authoritative in traditional sense

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Evaluating the Sources of Law

• Older cases
• Geometrically declining importance, except for
• Supreme Court cases
• 2nd, 9th and Federal circuits
• If it is the only precedent available
• Court decisions can be unpredictable

13
Evaluating the Sources of Law

• Tax treatises and journals
• Identify current, critical tax issues
• Can include comprehensive summary of controlling
  law
• IRS agents are only bound by
• IRC
• Administrative pronouncements
• Supreme Court decisions

14
Client Letters

• Telephone calls to clients are prevalent
• Should be followed up with a detailed letter
• Letter should be brief
• Sometimes easier to explain complicated issues in
  face-to-face meetings

15
Client Letters Format and Content

• Salutation/social graces/general conclusion
• Summary of results
• Objective of research
• Statement of facts/disclaimer

16
Client Letters Format and Content

• Summary of critical sources
• Implications of the results
• Assumptions/limitations
• Closing/reference to follow-up meeting/social
  graces
• Attachments

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Effective Written Business Communication

• Main point(s) in first paragraph
• State well-defined purpose
• Avoid filler language, clichés and jargon
• Revise several times if needed
• Use social amenities
• Use edit and proofreading aids

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Client File

• Client file includes
• Client letter
• File memo
• Engagement letter
• Billing and collection history
• Relevant authoritative sources
• Links to other important sources

19
Oral Presentations of Research Results

• General Preparation
• Why was I asked to speak?
• What do they want?
• What is their attitude?
• What do they already know?
• Who is the audience?

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Oral Presentations of Research Results

• Content delivery
• Know the technical aspects of the research
• Concentrate on main points
• Present only the highlights necessary to satisfy
  audience
• Use visual aids effectively (next slide)

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Oral Presentations of Research Results

• Using visual aids
• Do not constantly look at screen
• Avoid reading text of visual aid word for word
• Use the aid to focus audience on discussion
• Avoid having a blank screen

22
Oral Presentations of Research Results

• Use non-text visuals to illustrate items
  difficult to convey in words
• Save time by consolidating ideas
• Create interest in a subject
• Emphasize a point or concept

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Oral Presentations of Research Results

• Organize the presentation
• Introduce humor
• Visual take away items

24
Oral Presentations - Using Slides

• Emphasize pictures, not numbers
• Use graphs, charts, arrows, etc.
• The 6 x 6 rule for text
• Six lines per page
• Six words per line

25
Oral Presentations - Using Slides

• Use simple fonts
• Use simple color scheme
• Test technology before the presentation
• Prepare for the worst
• Number overhead slides
• Hard copy of computer slides
• Bring backup

26
Rehearsal and Presentation

• At least one dress rehearsal
• Use an audience or video camera
• Helps eliminate distracting mannerisms
• Positioning
• Get physically close to audience
• Move around during the presentation
• Eliminate nervous and visual distractions

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Rehearsal and Presentation

• Vary pitch of voice
• Short periods of silence are okay
• Do not read directly from outline
• Make eye contact with audience

28
Rehearsal and Presentation

• Be enthusiastic and positive
• Avoid clichés
• Be careful using jokes
• Observe audience body language