Help me with a tax memo please

Hello again, I chose you to do my tax memo again. I just need to provide you the topic I need you to talk about and the issues (questions) I need you to answer. You did a great job last time but unfortunately it was a different topic. Are you able to help me within 24 hours?
-Prepare a tax research memo addressing the question that has been raised.Please note that if the tax memo isnot in the required format and/or contains very little analysis you will receive a zero (0) for the assignment. Allgood faith efforts are capable of receiving a minimum of 60% but less than a good faith effort will be awarded zeropoints.
-You will need to support your conclusion using primary sources of tax law. Your textbook is NOT primary authoritynor are IRS Publications. Please refer to Chapter 2 for primary authorities. CCH AnswerConnect is not a primaryauthority, nor is Google Scholar nor are any other websites you may access. The primary authorities are legislative,administrative and judicial. I will attach the Chapter 2 for primary authorities in the thread.
I HAVE ATTACHED EXAMPLES OF THE MEMOS
-You must use proper citation form in your memo (see Chapter 2 for help with citation form). The form for thiscommunication should be professional and in the form of a tax research memo (examples posted on Canvas and asimilar example in your textbook). You will see that citations are within the text of the document in the example.Once a court case has been cited in full, it can be referred to using simply the name in italics.
-This memo should be whatever length you feel is appropriate to resolve the issues. We do NOT use a bibliographyor list of references in a tax research memo. We do not include Background in a tax memo. The Background isprovided so you can identify the facts.

it should be based on this client:
Background: Your client, George’s Mission Bay Island, Inc. (“GMBI”) has approached you for some tax advice about how to handle some new items on the income tax return for the business. GMBI is an S corporation. There is only one shareholder and the corporation has a calendar year end. The business uses the same records for books that are used for tax (the accounting records to do not conform to GAAP). The average gross receipts for the past three (3) years has been $10 million. GMBI uses the cash method for income tax purposes. Whenever possible GMBI is seeking to maximize expenses and minimize income each year – timing strategy. The shareholder of GMBI understands in 2021 it may be worthwhile to defer expenses to 2022 and accelerate income to 2021 in case income tax rates increase but the shareholder wants to maximize deductions in 2021 and minimize taxable income in 2021.
GMBI leases plots to Recreational Vehicle(“RV”) owners. During 2021 GMBI purchased some RVs from former lessees and refurbished the RVs and plans to resell them. It purchased five (5) RVs in 2021 and sold three (3) RVs from the initial purchase of the five (5) RVs in 2021, so that at the end of 2021 there were two (2) RVs that remain unsold. GMBI purchased the materials for the refurbishment from external suppliers. The refurbished RVs each sell for $200,000 and originally cost GMBI $70,000. The cost of supplies to refurbish each RV is $15,000, i.e. total cost in 2021 of $75,000. GMBI finances the sale to their customers with a promissory note with an interest rate of 8%, with a required 20% down payment and equal instalments of the remaining 80% of 20% for each of the next four (4) years, i.e. for the RVs sold in 2021 GMBI received 20% of the $200,000 for each of the three (3) RVs in 2021 with another 20% (plus 8% interest) in 2022, 2023, 2024 and 2025. The promissory is $160,000 plus 8% interest for each RV that was sold in 2021.
GMBI needs advice for the following for the 2021 income tax year:
1. What is the income tax treatment for the deduction of the costs of the supplies associated with the refurbishment of the RVs? How much of the $15,000 supply cost for each RV will GMBI deduct in 2021?
2. What is the income tax treatment for the sale of the refurbished RVs? How much sales revenue will GMBI recognize for the sale of the three (3) RVs in 2021?
3. Would it make a difference to the answer in #2 if GMBI did not receive a promissory note from the customer and instead made the sale agreement with the same terms of 20% down payment and 20% (plus 8% interest) for the next four years?
You research should consider the following (but it is not an exhaustive list):
IRC §61
Regs §1.61-1(a)
IRC §448(a)
IRC §448(c)
Regs §1.448-1
Regs §1.448-2(c)
IRC §471(a)
IRC §471(c)
Regs §1.471-1

Your responsibility: Prepare a tax research memo addressing the question that has been raised. Please note that if the tax memo is not in the required format and/or contains very little analysis you will receive a zero (0) for the assignment. All good faith efforts are capable of receiving a minimum of 60% but less than a good faith effort will be awarded zero points.
You will need to support your conclusion using primary sources of tax law. Your textbook is NOT primary authority nor are IRS Publications. Please refer to Chapter 2 for primary authorities. CCH AnswerConnect is not a primary authority, nor is Google Scholar nor are any other websites you may access. The primary authorities are legislative, administrative and judicial.
You must use proper citation form in your memo (see Chapter 2 for help with citation form). The form for this communication should be professional and in the form of a tax research memo (examples posted on Canvas and a similar example in your textbook). You will see that citations are within the text of the document in the example. Once a court case has been cited in full, it can be referred to using simply the name in italics.
Do yourself a favor and look at the grading rubric before you submit.
This memo should be whatever length you feel is appropriate to resolve the issues. We do NOT use a bibliography or list of references in a tax research memo. We do not include Background in a tax memo. The Background is provided so you can identify the facts.
The grading rubric for Tax memos is posted in Canvas. For this assignment, points are distributed as follows:
Aspects of the memo. Points
Content – facts and issue(s) 16
Content – analysis 30
Content – conclusion 14
Organization 8
Audience 8
Style 8
Mechanics 8
Referencing 8
Total 100

I WILL ATTACH EXAMPLES OF STUDENTS IN THE THREAD TO HELP.

The rubric:
Tax memo rubric
Tax memo rubric
CriteriaRatingsPtsThis criterion is linked to a Learning OutcomeContent – Facts and issuesAll pertinent facts and issues have been described in a clear and concise manner. Distinguishing features of the fact pattern are highlighted.
16 ptsFull Marks
14 ptsGood
13 ptsFair
Most critical facts and issues identified and communicated. Some unessential facts included.
11 ptsNeeds work
10 ptsPoor
Critical facts and issues omitted or substantial unessential facts and issues included. Unable to apply or distinguish from other possible fact patterns or facts are merely copied from case.
0 ptsLittle or no effort
Does not meet minimum requirements for effort
16 pts
This criterion is linked to a Learning OutcomeContent – AnalysisAll necessary references to authority have been made. Authority which could apply but does not has been distinguished from that which does. The analysis follows a logical pattern of application to the facts and supports author’s conclusion.
30 ptsFull Marks
All necessary references to authority have been made. Authority which could apply but does not has been distinguished from that which does. The analysis follows a logical pattern of application to the facts and supports author’s conclusion.
27 ptsGood
24 ptsFair
Analysis is incomplete or one-sided. Most relevant authority has been identified. Analysis is not perfectly logical or does not support issue stated.
21 ptsNeeds work
18 ptsPoor
Analysis is deficient in reference to authoritative tax law. Analysis lacks cohesion and does not support conclusion. Analysis relies on secondary sources when primary sources exist.
0 ptsLittle or no effort
Does not meet minimum requirements for effort
30 pts
This criterion is linked to a Learning OutcomeContent – ConclusionConclusion is clear and integrates with facts and analysis. More than a simple sentence stating conclusion. Cause and effect relationship between facts and analysis are made. All open issues are responded to. Conclusion drawn is correct.
14 ptsFull Marks
13 ptsGood
11 ptsFair
Conclusion fails to tie analysis and facts together. Some conclusions made as part of analysis instead of in conclusion.
10 ptsNeeds work
8 ptsPoor
Conclusion is unclear and unsupported by analysis. Reader is not able to form educated opinion on tax treatment of facts pattern. Conclusion is a simple sentence stating conclusion.
0 ptsLittle or no effort
Does not meet minimum requirements for effort
14 pts
This criterion is linked to a Learning OutcomeOrganizationPaper flows well with appropriate beginning, development, and conclusion. Paragraph structure contributes to flow and transitions. Organization and/or headings help the reader to understand and remember information.
8 ptsFull Marks
Paper flows well with appropriate beginning, development, and conclusion. Paragraph structure contributes to flow and transitions. Organization and/or headings help the reader to understand and remember information.
7 ptsGood
6 ptsFair
Paper follows logical sequence with identifiable beginning, development, and conclusion. Generally proper use of paragraph structure and topic sentences. Organization and/or headings help the reader to follow and find information.
5 ptsNeeds work
4 ptsPoor
Paper lacks logical sequence hence causing format to interfere with readability. Does not use proper paragraphing. Topic sentences do not lead to rest of paragraph or are missing altogether.
0 ptsLittle or no effort
Does not meet minimum requirements for effort
8 pts
This criterion is linked to a Learning OutcomeAudienceWriter clearly focuses writing to the audience, and displays empathy for the reader. Goodwill is created through consideration of the reader’s needs. Message tailored directly for the reader
8 ptsFull Marks
Writer clearly focuses writing to the audience, and displays empathy for the reader. Goodwill is created through consideration of the reader’s needs. Message tailored directly for the reader
7 ptsGood
6 ptsFair
Writer acknowledges the reader and displays some thought about the nature of the audience. Reader is treated politely and positively. No evidence of inappropriate attitude.
5 ptsNeeds work
4 ptsPoor
Writer is internally focused rather than focused on the reader. No clear awareness or understanding of the audience is evident. Writer may appear discourteous to the reader.
0 ptsLittle or no effort
Does not meet minimum requirements for effort
8 pts
This criterion is linked to a Learning OutcomeStyleDemonstrates a sophisticated grasp of the language in terms of both sentence structure and vocabulary. Writes fluidly and concisely. Includes appropriate business terms.
8 ptsFull Marks
Demonstrates a sophisticated grasp of the language in terms of both sentence structure and vocabulary. Writes fluidly and concisely. Includes appropriate business terms.
7 ptsGood
6 ptsFair
Sentences vary in length and style. Strong action verbs are used. Occasionally uses jargon or clichés. Vocabulary and word usage generally is correct and shows some variety. Uses business terms appropriately.
5 ptsNeeds work
4 ptsPoor
Overuse of simple sentences. May misuse words or idioms. May include slang. Wordy rather than concise. Writing shows lack of sophistication or variety in vocabulary. Awkward. Little or no use of business terms.
0 ptsLittle or no effort
Does not meet minimum requirements for effort
8 pts
This criterion is linked to a Learning OutcomeMechanicsNo errors in word usage, sentence structure (run-ons, fragments), spelling, punctuation, and capitalization. Strong mechanics help to establish credibility.
8 ptsFull Marks
No errors in word usage, sentence structure (run-ons, fragments), spelling, punctuation, and capitalization. Strong mechanics help to establish credibility.
7 ptsGood
6 ptsFair
Relatively free of errors in word usage, sentence structure (run-ons, fragments), spelling, punctuation, and capitalization. Mechanics do not detract from credibility of the content.
5 ptsNeeds work
4 ptsPoor
Significant errors in word usage, sentence structure (run-ons, fragments), spelling, punctuation, and capitalization. Errors undermine credibility of content and readability.
0 ptsLittle or no effort
Does not meet minimum requirements for effort
8 pts
This criterion is linked to a Learning OutcomeReferencingReferences (if called for) are consistently correct. No missing citations.
8 ptsFull Marks
References (if called for) are consistently correct. No missing citations.
7 ptsGood
6 ptsFair
Generally correct referencing (if called for).
5 ptsNeeds work
4 ptsPoor
References (if called for) are missing or do not use correct referencing style.
0 ptsLittle or no effort
Does not meet minimum requirements for effort
8 pts
Total Points: 100

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