Please write an internal research memo for this case: Michael Gordon Banks v. Commissioner, TC Memo 2019-166 (https://www.ustaxcourt.gov/UstcInOp/OpinionViewer.aspx?ID=12131).
Follow the format from Page 2-20 of your text. Be sure to include citations of at least 3 primary sources (i.e., Code, regulations, rulings, cases). Your essay should be at least 400 words. Graduate students should provide at least 5 primary sources and 550 words.