It is best to analyze the issues in your case by following the "IRAC" method lawyers are usually taught in law school. This analysis utilizes the following steps:

Issue -- 

Identify the issues from the Statutory Notice of Deficiency (stat notice). In most cases, the stat notice will set out the law by quoting a section from the Internal Revenue Code (IRC).

Rule of law -- 

For each issue, determine what the law requires the petitioner to prove. It is best to list each step the law requires. The law generally will consist of statutory law as set out in the IRC and case law as set forth by the Tax Court or other courts. Google can help you to determine the law in your case.

Analysis -- 

Apply the law to the facts in your specific case. This requires:

• Determining the facts that support each step in the rule

• Determining what evidence (documents and testimony) exists to present in court to support the facts

Conclusion -- 

Explain and summarize why your position should prevail.