Prompt Chain: Tax Research to Finished Memo in 4 Steps

I'm researching a tax question for a client matter. Please explain the following issue:

Tax question: [state your specific question]
Relevant facts: [describe the situation without identifying info — no names, SSNs, EINs]

For your response, please:
1. Identify the primary IRC sections that apply
2. Note any relevant Treasury Regulations
3. Describe the general rule in plain language
4. Note any exceptions, elections, or special rules that could apply
5. Flag if this area has had recent legislative or regulatory changes that I should verify

Based on the legal research above, now apply it to these specific facts:

Facts: [describe the client's specific situation in more detail — still no identifying info]

Please:
1. State how the general rule applies to these facts
2. Note any facts that are unclear or that would change the analysis
3. Identify the strongest and weakest points in this tax position
4. State your conclusion: what is the likely tax treatment?

Using the research and analysis from our conversation, draft a formal tax research memo with these sections:

ISSUE: [one sentence statement of the question]
FACTS: [use these exact facts: [paste your client facts — still anonymized]]
LAW AND ANALYSIS: [based on Step 1 and Step 2 outputs]
CONCLUSION: [based on Step 2 analysis]

Format it as a formal memo that could go into a client file. Use professional language appropriate for a CPA firm.

Review this memo draft and:
1. Check that each section flows logically from the previous one
2. Ensure the conclusion follows clearly from the analysis
3. Identify any statements that need to be verified in primary sources (IRC, regulations, IRS guidance)
4. Note where I should add client-specific information before finalizing
5. Flag any overstatements or unsupported conclusions

[Paste the Step 3 draft here]