Federal Tax Research 10th Edition by Steven Gill, Gerald Whittenburg, Roby Sawyers, Debra Sanders, William Raabe

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Ned Naive operated several franchised stores, and at the home office's suggestion he consolidated the stores' payroll and accounting functions with Andy the Accountant. Andy is not a CPA. Last year, Andy began embezzling taxpayer's escrowed tax withholdings and failed to remit required amounts for the four quarters. The IRS assessed Ned $10,000 in penalties for failing to make the proper withholding deposits during the year.
After appropriate research, prepare (in good form) a research memorandum to the file. (See Chapter 2 for an illustration of the structure of a tax memo.) Then write a letter to Ned explaining your findings. His address is 4567 Brainless Street, Phoenix, AZ 91234.