The memorandum should include a very brief explanation of the relevant facts,

The memorandum should include a very brief explanation of the relevant facts, Tax/Research Issue(s), Conclusion, and Analysis. In total your memorandum should be no longer than 1- 1 ½ pages (1.5 space and font no smaller than 10)
The relevant facts are:ABC’s Corporation has a policy of furnishing new automobiles to the athletic department of the local University. The automobiles are used for short periods of time by the extremely popular head basketball coach. When the automobiles are returned to Berkeley Corporation, they are sold to regular customers. The owner of Berkeley Corporation maintains that any such cars held for more than one year should qualify as Section 1231 property.How would you advise? In your memo, please include the tax consequences if it is allowed and the tax consequences if it is not allowed before coming to your conclusion
Hint – you will find guidance from the following sources of tax law.
You will find guidance in:Revenue Ruling 75-538. Duval Motor Co. v. Commissioner, 28 T.C. 42 (1957);
A copy of these is attached. If you feel that you need additional authority to make a definite conclusion- feel free to include other research- but if you do include any additional research, make sure to provide a works cited page. Please state any assumptions that you are making. Your review on this assignment will be determined as follows:Professional Format, Clearly Written, Identification of Issue/ Correct Solution, andCitation of appropriate provisions