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A new client, Brice, has come to you seeking assistance because he recently received a letter from the IRS informing him that he failed to file Federal Income Taxes for the last 3 years. Brice lives in Key West, FL and is a financial analyst for a large telecom company and earned his B.S. degree in Accounting from UCF in 2015. During your initial meeting with Brice, you asked him why he hasn’t filed federal income taxes. He informs you that he has done considerable research into federal income taxes and has come to the conclusion that since he is a citizen of the “Conch Republic,” he is not a citizen of the United States and is therefore not subject to federal income taxes.
Instructions:
Write a tax memo following the example on page 2-20 in the textbook and address the client’s current claims. Identify the relevant statutory, administrative, and judicial authorities to justify your holding. Make sure to thoroughly document the basis of your finding through citing the Internal Revenue Code. Extensive case law research is not necessary but include at least one case that supports your holding. The tax research memo should be no more than 2 pages long.
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