For this assignment, you will be submitting a tax research memo regarding the scenario detailed below. The memo will be due by 11:59 p.m. (ET) on Sunday Module/Week 6. The purpose of this assignment is for you to research the proper method for calculating deferred tax assets and liabilities.

The memo should be submitted in the form of a Microsoft Word document, using only the template provided, and labeled as follows: lastname_memo3.doc. The Relevant Facts, Specific Issues, and Conclusions sections of the memo should be thorough but concise. The key portion of the memo will be the Support section, which should be properly supported by appropriate regulation citations (be specific with section, number, paragraph, and subparagraph as applicable).

As this is a memo, and not a formal writing assignment, APA format is not required. Furthermore, there is no need to submit a title page or research page. Just substitute “Your Firm” at the top of the memo with your full name.

Prepare (in good form) a research memorandum to the file.

SCENARIO: Altidore Inc. operates a calendar-year-end business that suffers from dramatic seasonal variation in taxable income. For example, it often operates at a net loss for the first two quarters of the year and then operates profitably for the last two quarters and, for as long as anyone can remember, finishes the year with taxable income. The new tax director has been asked to help calculate the deferred tax assets at the end of the first quarter. After looking at the quarterly loss, he claims that since there is no net income, there are no deferred tax assets because the effective tax rate is zero. (Carrybacks and carryforwards are not allowed in this jurisdiction.) Is the tax director correct in his assessment of the effective tax rate for calculating the deferred tax assets?

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