Tax Research Memo (Workpaper), TEMPLATE
How to use. This is the Step 6 documentation artifact from Module 2, Tax Research. It turns an AI-assisted research session into a defensible workpaper: a record of the issue, the facts, the verified authorities, the analysis, and the conclusion, with sign-off. Fill every
[BRACKET]; delete guidance notes. The point of the "Verified?" column is that nothing load-bearing goes in this memo until a human confirmed it against a primary source. Not legal/tax advice as a blank template.
[FIRM NAME], Tax Research Memorandum
| Field | Entry |
|---|---|
| Memo #/Workpaper ref | [___] |
| Client / matter | [name or anonymized reference] |
| Tax year(s) | [___] |
| Prepared by | [name, credential] · Date: [___] |
| Reviewed by (reviewer of record) | [name, credential] · Date: [___] |
| AI assistance used? | [Yes/No, tool(s) and how, e.g., "Claude Team, issue mapping & drafting from verified sources"] |
1. Issue(s)
[State the precise tax question(s). Keep it abstract where possible.]
2. Facts
[Relevant facts only. If client-identifiable facts were entered into any AI tool, note which tool
(must be firm-approved) and the §7216/confidentiality basis. Otherwise note "anonymized, no TRI
entered."]
3. Authorities considered, and verification record
Every authority load-bearing on the conclusion must be verified against a primary source and marked ✅ before it supports the analysis. Unverifiable cites are removed.
| Authority (cite) | Type (Code/Reg/Ruling/Case/Other) | Proposition relied on | Verified against primary source? | Still good law? |
|---|---|---|---|---|
[e.g., IRC §199A(b)(2)] |
Code | [___] |
✅ [law.cornell.edu …] |
✅ [checked …] |
[e.g., Treas. Reg. §1.199A-1] |
Reg | [___] |
✅ [ecfr.gov …] |
✅ |
[e.g., Rev. Proc. 2013-14] |
IRB | [___] |
✅ [irs.gov/irb …] |
✅ |
[case] |
Case | [___] |
✅ [ustaxcourt.gov / CourtListener] |
✅ |
Non-authoritative sources used only for orientation (IRS Pubs, FAQs, AI output): [list, or "none
relied upon"].
4. Analysis
[Apply the verified authorities to the facts. Cite to the specific provision for each step. Include
the contrary/devil's-advocate position and why it does or doesn't prevail. Note any areas of
uncertainty or where authority is mixed.]
5. Conclusion
[The answer, stated clearly, with the level of confidence and any conditions/assumptions. Note the
authority weight, e.g., supported by substantial authority, where penalty exposure is relevant.]
6. Open items / follow-up
[Facts to confirm, later guidance to monitor, or questions for the client.]
Reviewer sign-off
By signing, the reviewer confirms the authorities were independently verified against primary source, the analysis is sound, and the conclusion is the firm's, not an unreviewed AI output.
Reviewer: __________________________ Credential: ________ Date: ____________
Template maintained with the AI Lab for Accountants library. See Module 2, Tax Research and Regulatory Foundation. Not legal/tax advice.