Build the issue/rule/analysis/conclusion memo from a messy client email

1 · Learn the move · Template pattern

A client email is a story. A memo is four sections, and the model is good at turning the one into the other if the shape is fixed and the rules are stated. ISSUE: the question, restated narrowly, in one sentence, with the taxpayer de-identified before the email ever reached the tool. FACTS: only what the email says, with [NEEDS] for what the answer turns on and the email does not say. RULE: the authorities, each marked VERIFY, sorted SETTLED, CONTESTED, OPEN. ANALYSIS: the rules applied to the facts, in the conditional wherever the fact is a [NEEDS] or the rule is not SETTLED. CONCLUSION: what follows, with the open items listed, never a number the email did not contain. The model drafts; the memo's conclusions are yours after you open every authority and fill every [NEEDS]. The one thing the template refuses: it never invents a fact to make the analysis cleaner. A messy email produces a memo with holes in it, and the holes are the work.

Turn this de-identified client email into a research memo with four sections: ISSUE (one sentence, narrow), FACTS (only what the email says; [NEEDS: ...] for every fact the question turns on and the email does not give), RULE (the authorities, each VERIFY, each labelled SETTLED / CONTESTED / OPEN), ANALYSIS (rules applied to facts, in the conditional wherever a fact is [NEEDS] or a rule is not SETTLED), CONCLUSION (what follows; the open items; no figure the email did not contain). Do not invent a fact. Do not state a threshold or rate; write [NEEDS: the figure, with source and year].