November 12, 2002

2002 Law Student Tax Challenge

Problem, Semi-Finalist Answers, ABA Tax Times Report

Background and Entrants

The American Bar Association Section of Taxation Young Lawyers Forum held the final rounds of the second annual Law Student Tax Challenge on January 24, 2003, during the Section's Midyear Meeting in San Antonio, TX. Law students from across the country competed.

Of the 29 teams that entered the Challenge, four semi-finalist teams were selected to compete orally in San Antonio.

The semi-finalist teams were:

  • Chistopher Bourell and Gianna Ravenscroft, Southern Methodist University
  • Chris Hayes and Rhia Winant, Stetson University
  • Thomas Newman and Thomas Greenaway, University of Connecticut
  • Jeremy S. Dardick and Erika L. Andersen, University of Michigan

Finalists and Winners

The teams from Southern Methodist University and the University of Michigan were chosen to proceed to the final round.

In the end, the University of Michigan finished in first place overall, with the SMU team winning second place.

Judges

Judges for the 2002 competition included some of the nation's top tax law practitioners. Here we present biographical information on the tax professionals who acted as judges for the semifinal and final rounds.

  • Michael M. Lloyd is an Associate in the Washington, DC office of Baker & McKenzie. His practice focuses on federal and international tax planning, tax controversy and litigation. Mr. Lloyd is admitted to practice law in Maryland and the District of Columbia. He is also a certified public accountant in Maryland.Mr. Lloyd is a 2001 honors graduate of the University of Maryland School of Law and a 1991 graduate of Mount St. Mary's College. He is an active member of the American Bar Association Section of Taxation and a Member of the ABA Tax Section's Young Lawyer's Forum.
  • Pamela F. Olson, Assistant Secretary for Tax Policy, has supervisory responsibility for providing the Secretary of the Treasury with policy analysis, advice and recommendations relating to all aspects of domestic and international issues of Federal taxation, including all legislative proposals, regulatory guidance, and tax treaties. The Assistant Secretary for Tax Policy is also responsible for providing the official estimates of all Government receipts for the President's budget, fiscal policy decisions, and Treasury cash management decisions.

    Olson joined Treasury as the Deputy Assistant Secretary for Tax Policy in February 2001. She has served as the Acting Assistant Secretary for Tax Policy since April 2002. Prior to her appointment as Deputy Assistant Secretary, Olson was a partner in the Washington, D.C. office of Skadden, Arps, Slate, Meagher & Flom, LLP. She previously held positions with the Chief Counsel's office of the Internal Revenue Service as Special Assistant to the Chief Counsel, as an Attorney-Advisor in the Legislation and Regulations Division, and as a trial attorney in San Diego District Counsel.

    Olson is a member of the Bar of the District of Columbia, United States Tax Court, and United States Supreme Court. She served as Chair of the American Bar Association Section of Taxation immediately prior to her Treasury appointment, the first woman to hold the position. She is a Fellow of the American College of Tax Counsel; a Fellow of the American Bar Foundation; and served as a Trustee of the American Tax Policy Institute. She is a frequent speaker on continuing legal education topics and has published several articles. She also served as federal tax advisor to the National Commission on Economic Growth and Tax Reform. Pam received a B.A. magna cum laude (1976), J.D. (1980), and M.B.A. (1984) from the University of Minnesota. In 2002, she was awarded the University of Minnesota's Outstanding Achievement Award.
  • Stephen L. Owen practices in the Baltimore, Maryland and Washington, D.C. offices of Piper Rudnick LLP where he serves as Chair of the Business Tax Practice Group. He practices primarily in the areas of mergers and acquisitions, corporate and partnership transactions, real estate tax planning, joint ventures, and business and estate planning for closely-held enterprises and their owners. Mr. Owen has written on a variety of tax and business topics, including extensive works on corporate, partnership and real estate taxation, and estate planning in various professional journals. He is a member of the editorial boards of The Journal of Real Estate Taxation, The Journal of Pass-Through Entities and The Practical Tax Lawyer. He is a frequent speaker on tax and business topics at nationally recognized programs including The Southern Federal Tax Institute, N.Y.U. Real Estate Tax Institute, The Texas Federal Tax Institute, The New Jersey Tax Institute, The North Carolina Tax Institute, The Tennessee Tax Institute and The Kentucky Tax Institute. Mr. Owen is listed in The Best Lawyers In America and is a member of the American College of Tax Counsel. Mr. Owen is the Chair of the Partnerships Committee of the ABA Section of Taxation and a past Chair of the Section of Taxation of the Maryland State Bar Association.
  • Christopher M. Pietruszkiewicz is an Assistant Professor of Law at the Paul M. Hebert Law Center, Louisiana State University where he currently teaches Tax Practice & Procedure, Corporate Tax, Income Tax, and Accounting for Lawyers and writes in the area of taxation. He is a former Trial Attorney for the United States Department of Justice, Tax Division and Adjunct Professor of Law at the George Mason University School of Law. He received a Bachelor of Science in Accounting at the University of Scranton, a J.D. at the Loyola University School of Law in New Orleans, and an LL.M. (Tax) at the Georgetown University Law Center.
  • William M. Richardson is a partner in Hunton & Williams, resident in the law firm's Richmond, Virginia office. He is a graduate of the College of William and Mary (A.B. 1974) and the University of California, Hastings College of the Law (J.D. 1978). Admitted to the Virginia Bar in 1978, he clerked at the Supreme Court of Virginia from 1978 to 1980, and joined Hunton & Williams in 1980. His practice focuses on federal income tax law, with emphasis on corporate acquisitions and reorganizations, financings, and controversy proceedings. A Fellow of the American College of Tax Counsel, he is Chair of the Corporate Tax Committee of the American Bar Association's Section of Taxation for 2002-2003.
  • Walter D. Schwidetzky is a Professor of Law at the University of Baltimore School of Law, where he currently teaches corporate, partnership, and Federal income taxation. He also serves as Chair of the Post-Tenure Review Committee and is a past member of the school's Provost Council. Prior to his academic career, Schwidetzky was a partner in the Denver firm of Ellis, King and Schwidetzky. He is admitted to practice in Colorado, and before the Tax Court, Federal Court, and Tenth Circuit Court of Appeals. He holds a B.A. (1974), M.B.A. (1978), J.D. (1978), and LL.M. in Taxation (1984) from the University of Denver. He is a member of the ABA Section of Taxation Partnerships Committee.
  • Barbara Spudis de Marigny is a shareholder with the San Antonio law firm of Oppenheimer, Blend, Harrison & Tate, where she practices in the area of federal income tax planning and specializes in the taxation of partnerships and limited liability companies. Previously, she was a partner in the Chicago office of Baker & McKenzie. She received her B.A. degree from Duke University in 1978 magna cum laude, her J.D. degree from the University of Virginia in 1981 and her L.L.M. in Taxation from IIT Chicago - Kent School of Law in 1986. She is the immediate past Chair of the Partnership Taxation Committee of the ABA Section of Taxation and the former Chair of the Task Force on Limited Liability Companies. Ms. de Marigny has written and spoken extensively on a variety of federal income tax planning topics.
  • B. John Williams, Jr., is currently serving as President George W. Bush's appointee as Chief Counsel, Internal Revenue Service, Washington, DC. Mr. Williams came to government service from the law firm of Shearman & Sterling, where he headed the tax litigation practice. His prior government service includes serving as a Judge on the U.S. Tax Court from 1985-1990, as a Deputy Assistant Attorney General in the Tax Division of the Justice Department from 1983-1984, and as the Special Assistant to the Chief Counsel of the Internal Revenue Service from 1981-1983.

    Mr. Williams received his B.A. from George Washington University (with distinction, university honors and departmental honors in history) in 1971. He is a member of Phi Beta Kappa and Omicron Delta Kappa. He received his J.D. from George Washington University Law School (with honors) in 1974 where he was a member of the law review. He is a member of the District of Columbia, Pennsylvania, U.S. Tax Court, U.S. Court of Federal Claims, U.S. Courts of Appeals for the Third, Ninth and Federal Circuits and U.S. Supreme Court Bars. Mr. Williams is also associated with the American College of Tax Counsel, American Law Institute and the American Bar Association's Tax Section.