USE THE FOLLOWING FORMAT:
(See Exhibit 2-9, Sample Research Memo, on page 2-21 of text, for more details)

MEMO #: 4
GROUP #: 7 / Writer: Jabari Brown / Reviewers: ________________________
FACTS: Connie Cook owns her own marketing consulting business that she runs out of her home. She paid $15,000 to join a country club in order to meet potential marketing clients. This year Connie also paid $4,300 in greens fees when golfing with clients.
ISSUE: Can Connie deduct the $15,000 cost of country club dues and the $4,300 for the golf played with clients?

AUTHORITIES: 1. Pension Federal Tax Regulations, regulation,§1.274-2.,Internal Revenue Service, Disallowance of deductions for certain expenses for entertainment, amusement, recreation, or travel 2. Pension Federal Tax Regulations,regulation,§1.274-2.,Internal Revenue Service, Disallowance of deductions for certain expenses for entertainment, amusement, recreation, or travel

CONCLUSION: Connie will be able to deduct the cost of the country club dues and the green fees.
ANALYSIS: When dealing with country club memberships and greens fees for business the tax law this fall under would be Disallowance of deductions for certain expenses for entertainment, amusement, recreation, or travel. The Pension Federal Tax regulation in the general rule section states that no deduction shall be allowed for what are considered entertainment activities unless the taxpayer establishes that the expenditure was directly related to the active conduct of the taxpayer’s trade or business. In section 2 of the same regulation is gives requirement for Entertainment Facilities. The section states no deduction shall be allowed for entertainment facilities unless the facility or club was used primarily for the furtherance of the taxpayer’s trade or business. Connie spending $15,000 on a country club memberships