need to write the memo for federal tax Academic Help

Help me study for my Law class. I’m stuck and don’t understand.

Need to write the memo using the same format as attached here. Need to write in own words. Don’t cite from websites or anything, cite from primary sources like journals or case study; recommend using school library database. Use section and subsection to cite not the website. follow the guidelines in the memo and here is the situation:

Alison and Jim Smith are avid antiques collectors. They regularly attend garage sales and flea markets and purchase bunches of old stuff. In 2017, they purchased a very old desk for $600. The desk was in poor shape and required rehabilitation. It sat in their garage for more than a year. Alison was taking the desk apart when she found an old document jammed into a dark recess of the desk. She opened the document and much to her surprise she had found a very old copy of the Declaration of Independence.

Alison was very excited by this incredible historical treasure. She and Jim contacted Sotheby’s, the auction house, to get an appraisal for the document. In December 2018, Sotheby’s authenticated and appraised the letter at $ 1,350,000. In April of 2019, the letter was auctioned by Sotheby’s and fetched $ 1,650,000 net of fees and commissions. Alison and Jim received the money in May of 2019.

The Smiths would like to know how much and what type of income to report in which tax year(s) on their joint return.