Below are the facts for a file memo. A file memo is discussed in your text and should take the format of – Facts, Issues, Analysis and Conclusion. The analysis should contain the law, etc. you used to arrive at your conclusion. remember you are writing this for other tax people, so it should be technical in nature.
Gary and Greta Grumpy are a married couple who reside in Hinderland, USA. Both of them own a separate C Corporations. The corporations operate out of the Grumpy’s home and pay rent for office space in the home. In addition to their C corporations, the Grumpy’s own five rental properties, which have operated at a loss for the previous five years. Gary and Greta have been using the losses from these rental properties to offset the rental income they have been charging their corporations for operating in their home. On their last three individual tax returns, the Grumpy’s have shown income from the leasing office space to their C Corporations of $40,000, $24,000 and $22,000. The losses from the rental properties have been in excess of the income from the leased office, thus the couple has a passive loss carryforward of some amount; however, they did offset the lease income with the losses from the rental properties. Please give the tax issues and your advise in a tax memo format for the file.
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