Hello! I need help with this memorandum on the picture Here is the steps Please

Question

Hello! I need help with this memorandum on the picture Here is the steps Please write a short introduction introducing the client, the facts, and the issue. The introduction should be no longer than three or four sentences 1. Summary of the facts Write a summary of relevant facts. 2. Issues If there is only one issue, simply write the issue as a question, if there are multiple issues, write each issue as a question, and list each question. You might want to incorporate the main section, regulation, or court opinion that applies to the issue as part of the question. 3. Application The application should be organized according to the issues 4. Conclusion The conclusion should also be organized issues, the conclusion should answer the issue and point out pros and cons of the solution according to the

Explanation / Answer

Introduction:

Our client is Asylum Inc., a mental healthcare institution situated in Arkham, Texas. In it's heydey it was state's foremost mental healthare institution. Then due to questions on the doctor-patient ethics and on the safeguarding of the patients, the reputation of the institution was tarnished. tly States stopped sending patients to the asylum, which has placed it under financial stress.

Summary of the facts:

Asylum filed its Employer's Quarterly Federal Tax Return the quarter ending 31st December 2016 , but it failed to pay the tax of $110,000 reported in the return. InAugust 2017, IRS assessed the tax reported in the return and issued a Letter 1058, Final Notice- Letter of Intent to Levy informing the intent to take over Asylum's property.

Issue:

1) Whether Asylum's economic hardships be made ground for challenging the proposed levy?

2) If Yes, then would it work in favour of the Asylum Inc or not?

Application:

Asylum's Inc economic hardships can be made the ground for challenging the proposed levy. Since even the state's has stopped sending the patients to Asylum substantially affecting the Asylum's finances. And if the levy is imposed over Asylum's assets, even the current patients would be transferred to different mental healthcare institutions.The most propable solution to the problem is to enter into an installment agreement to avoid levies until a method for dealing with the problem can be devised.

Conclusion:

In conclusion, such settlement should most propably work in favour of the Asylum, as this would save the Asylum Inc from the levy on its assets. But simultaneously the Asylum would have to arrange for sufficient funds to settle the agreed upon installment amounts.

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