November 06, 2008

2008 Law Student Tax Challenge

Problem, Best Written Winners, Entrants

Finalists and Winners

We are pleased to announce the winners of the 2008 Law Student Tax Challenge:

J.D. Division Results

  • The 1st Place Team was Tonita Northington and Teri Ellison of Louisiana State University Law Center.
  • The 2nd Place Team was Mary Riley and Cathryn Streeter of Northern Illinois University College of Law.
  • The 3rd Place Team was Gainey Johnson and Travis Combs of University of Houston Law Center.
  • The Best Written Submission was by Jed Tomkins and Luke Jones of Lewis and Clark Law School.

The J.D. semi-finalists were:

  • Craig Standish and Matthew Brigham - Syracuse University College of Law
  • James Parker and Carl Potenza - Quinnipiac University School of Law
  • Jed Tomkins and Luke Jones - Lewis and Clark Law School
     

LL.M. Division Results

  • The 1st Place Team was Kelley Miller and Michael Gitlin of Georgetown University Law Center.
  • The 2nd Place Team was Jeffrey Malo and Agnieszka Samoc of Georgetown University Law Center.
  • The Best Written Submission was by Jeffrey Malo and Agnieszka Samoc of Georgetown University Law Center.

The LL.M. semi-finalists were:

  • Sonia Chien and Michele Hyndman - Georgetown University Law Center
  • Stewart Brant and Christopher Armstrong - University of Florida Levin College of Law

Judges

The Section thanks its members who gave of their time to assess the semi-finalist and finalist teams during the oral rounds of the 2008 Law Student Tax Challenge.

  • Hon. John O. Colvin, Chief Judge, United States Tax Court, Washington, D.C.
  • Hon. Juan F. Vasquez, Judge, United States Tax Court, Washington, D.C.
  • Hon. Peter J. Panuthos, Chief Special Trial Judge, United States Tax Court, Washington, D.C.
  • Nathan J. Hochman, Assistant Attorney General, Tax Division of the United States Department of Justice, Washington, D.C.
  • Donald L. Korb, Partner, Sullivan & Cromwell; Former Chief Counsel, Internal Revenue Service, Washington, D.C.
  • William H. Caudill, Partner, Fulbright & Jaworski, LLP, Houston, TX
  • Juan F. Vasquez, Jr, Shareholder, Chamberlain, Hrdlicka, White, Williams & Martin, Houston, TX
  • Kelley Cooper Miller, Associate, Sutherland, Asbill and Brennan, Washington, D.C.
  • Richard Lipton, Partner, Baker & McKenzie LLP, Chicago, IL
  • Deborah A. Butler, Associate Chief Counsel (Procedure & Administration), IRS Office of Chief Counsel, Washington, D.C.
  • Charles P. Rettig, Partner, Hochman, Salkin, Rettig, Toscher & Perez, P.C., Beverly Hills, CA
  • Armando Gomez, Partner, Skadden, Arps, Slate, Meagher & Flom LLP, Washington, D.C.
  • Thomas D. Greenaway, KPMG, Boston, MA
  • Adam M. Cohen, Holland & Hart LLP, Denver, CO

Judge Biographies

  • Judge Colvin was first appointed to the Tax Court in 1988 by President Reagan; he was reappointed to a second fifteen-year term in 2004 by President Bush. In February 2006, the Judges of the Tax Court elected Judge Colvin to be Chief Judge for a two-year term, beginning in June 2006.

    Before joining the Tax Court, Judge Colvin served as Tax Counsel for Senator Bob Packwood, Chief Counsel, and Chief Minority Counsel for the Senate Finance Committee. He has been an adjunct professor of law at Georgetown University Law Center since 1987. 
  • Juan F. Vasquez was nominated as a Judge to the U.S. Tax Court by President William J. Clinton on September 14, 1994, and confirmed by the Senate Finance Committee on March 17, 1995. He was sworn in as a Judge on May 1, 1995.

    Prior to his appointment, Judge Vasquez was in private practice representing clients in tax controversies before the Internal Revenue Service and the U.S. Tax Court. He worked with the Office of Chief Counsel, IRS, Houston office, 1978- 1982.

    In 1984, Judge Vasquez became certified in tax law by the Texas Board of Legal Specialization. In 1976, he received a CPA certificate from the State of Texas. He has been a member of the Austin IRS District/Practitioners Liaison Committee and its Chairperson in 1991. He served as the Treasurer of the San Antonio Mexican American Bar Association (MABA) from 1982 to 1994, and State chapter of MABA from 1986 to 1988.

    Judge Vasquez is currently a member of the ABA Tax Section and the Federal Trial Judges Section, National Hispanic Bar Association, Hispanic Bar Association of the District of Columbia, State Bar of Texas, Texas Bar Foundation, and San Antonio Bar Foundation (Life Fellow).
  • Hon. Peter J. Panuthos. Special Trial Judge. b. New York, 1943. Attended public schools in New York City; graduated from Erasmus Hall High School, 1961; attended Bernard Baruch School of Business of CUNY, B.S., Bryant College, Providence, RI, 1966; J.D., Suffolk University Law School, Boston, MA, 1969; LL.M., Taxation, Boston University School of Law, 1972; member of the Law Review. Admitted to Supreme Judicial Court of Massachusetts, District of Columbia Bar and United States Supreme Court; member of American Bar Association, Federal Bar Association, Inns of Court. Trial Attorney and Assistant District Counsel, Boston Office of Chief Counsel, Internal Revenue Service, 1970-83. Appointed Special Trial Judge, United States Tax Court, on June 12, 1983. Works with clinical and pro bono programs throughout the country. Works with the American Bar Association and appropriate committees to assist low income litigants. Participant and speaker at conferences relating to clinical programs. Taught Tax Procedure and substantive tax courses as an adjunct professor, at Bentley College in Boston, the Catholic University of America, Columbus School of Law and the David A. Clarke School of Law, University of District of Columbia. Served as Chief Special Trial Judge from June 1, 1992, to the present.
  • Nathan J. Hochman. From 1990 to 1997, Nathan Hochman was an Assistant United States Attorney, Criminal Division for the Central District of California. Over 10 years ago, Mr. Hochman left his government post to join the law firm of Hochman, Salkin, Rettig, Toscher & Perez, P.C. In January of this year, it was announced that Mr. Hochman would be returned to government service to assume his new role in Washington, D.C. as Assistant Attorney General for the Tax Division of the United States Department of Justice. At Hochman, Salkin, the 44-year-old tax law practitioner and government criminal attorney handled numerous tax, business, and white-collar criminal cases on behalf of the firm's corporate and individual clients. Mr. Hochman has been certified by California as a specialist in Criminal Law, has tried over 25 cases, and argued over 20 appeals to the Ninth Circuit Court of Appeals.
  • Donald L. Korb. Now a partner at Sullivan & Cromwell, Donald Korb is the former Chief Counsel for the IRS. As the chief legal advisor to the IRS Commissioner on all matters pertaining to the interpretation, administration and enforcement of the Internal Revenue laws, as well as all other legal matters, the Chief Counsel provides legal guidance and interpretative advice to the IRS, Treasury and to taxpayers. Before joining the IRS, Mr. Korb was a partner in the taxation practice area of the law firm of Thompson Hine. He has more than 30 years of experience in the practice of tax law, and before becoming Chief Counsel, focused his practice on handling taxpayer examinations, appeals, litigation, criminal tax and other contested matters, advising clients on prospective transactions, and obtaining rulings and other technical guidance from the IRS National Office.
  • Bill Caudill, who practices in Fulbright & Jaworski, LLP's Houston office, has a general tax practice, involving partnerships, oil and gas, real estate and tax-exempt organizations and work with the Internal Revenue Service. A partner since 1986, he also assists clients in bankruptcy and financially troubled commercial transactions. Mr. Caudill has chaired the State Bar of Texas' Section on Taxation and the ABA Tax Section's Committee on Partnerships and LLCs. He is a Fellow of the American College of Tax Counsel. Mr. Caudill is listed in Who's Who in America and The Best Lawyers in America. He was named as a "Top 100 Houston Region Super Lawyer" in the November 2003 issue of Texas Monthly. Mr. Caudill was also named as a "Texas Super Lawyer" in Tax Law in the November 2003 issue of Texas Monthly. Mr. Caudill was the principal drafter of the ABA Tax Section's comments on the Partnership Anti-Abuse Regulation.
  • Juan F. Vasquez, Jr. practices Tax Controversy in the Houston office of Chamberlain, Hrdlicka, White, Williams & Martin. He serves as Chair of the Houston Bar Association Section of Taxation, President Elect of the Mexican American Bar Association of Houston, Treasurer of the Hispanic Bar Association of Houston, and is past Chairman of the IRS Tax Practitioner Study Group. Mr. Vasquez was recently honored to be named as a 2008-2009 Nolan Fellow by the ABA Section of Taxation.

    Mr. Vasquez is a Big Brother with Big Brothers Big Sisters of Greater Houston and has the great honor to sit on the Board of Directors, where he also serves as Chair of the Audit Committee. Mr. Vasquez is also on the Board of Directors of the Houston Business and Tax Law Journal.

    Mr. Vasquez was mentioned as a leading individual in the Tax Litigation Nationwide category, in the Chambers USA’s “America’s Leading Lawyers for Business” 2006 and 2007 Client Guide. He was also named a “Texas Rising Star” by Texas Monthly. 
  • Kelley Miller practices Tax Planning and Controversy in the Washington, D.C. office of Sutherland, Asbill and Brennan.

    From 2006-2008, Ms. Miller served as the Attorney Advisor to The Hon. Stanley J. Goldberg of the United States Tax Court in Washington, D.C. Prior to her tenure at the Court, Ms. Miller was an Associate in the Washington, DC office of Powell Goldstein, where she served as editor and contributor to Joint Ventures Involving Tax Exempt Organizations by Michael Sanders (Wiley, 2006).

    As a student at Georgetown University Law Center, Ms. Miller was a Senior Executive Editor of The Tax Lawyer, and has written several articles on issues involving Federal tax law. Ms. Miller is a guest lecturer in tax at Georgetown University Law Center, where she teaches Taxation of Charities. She is a member of the Adjunct Faculty at Western New England College School of Law where she teaches Partnership Taxation and Estate Planning.

    Ms. Miller was the 2006 National First Place Winner of the American Bar Association Section of Taxation’s Law Student Tax Challenge Competition (LL.M. Division).
  • Dick Lipton has handled numerous engagements for clients in a variety of industries in structuring corporate and real estate transactions and providing legal advice relating to tax planning for partnerships and limited liability companies, as well as like-kind exchanges. Mr. Lipton also has considerable experience in the areas of real estate investment trusts (REITs) and investment in real estate by tax-exempt organizations and foreign investors. He has represented large corporations in complex partnership transactions, and has served as an expert witness on matters concerning partnerships and partnership taxation. He also has expertise in a number of other areas relating to tax law, including tax-exempt organizations and the rules involving UBIT, the tax consequences of bankruptcies and workouts and various tax accounting issues. 
  • Deborah A. Butler is the Associate Chief Counsel (Procedure and Administration). Ms. Butler was appointed Associate Chief Counsel in July 2000. In this position Ms. Butler oversees a staff of approximately 225 attorneys, managers, paralegals, and other employees within the Office who provide legal services to the IRS, other components of the Chief Counsel’s office, other government agencies, and the public in the areas of federal tax procedure and administration. The responsibilities of this office include matters relating to the reporting and payment of taxes; assessment and collection of taxes; the abatement, credit or refund of over-assessments or overpayments of taxes; the filing of information returns; bankruptcy; disclosure; FOIA; privacy law; litigation sanctions; ethics; and liaison with the courts. 
  • Chuck Rettig specializes in tax controversies as well as tax, business, charitable and estate planning, and family wealth transfers. His representation includes Federal and state civil and criminal tax controversy matters and tax litigation, including sensitive tax-related examinations and investigations for individuals, business enterprises, partnerships, limited liability companies, and corporations.

    Chuck is a frequent lecturer before national, state and local professional organizations and has authored articles in many national, state and local publications. Chuck has been quoted with respect to tax-related matters by the Wall Street Journal, the Los Angeles Times, Forbes, Tax Analysts-Tax Notes, the BNA Daily Tax Report the Los Angeles Times and other national and local periodicals. As stated in the Chambers USA 2007 Guide, "According to peers, Charles Rettig of small tax controversy boutique Hochman Salkin Rettig Toscher & Perez is ‘phenomenal, just phenomenal.' He has a ‘tremendous reputation' for his work which is primarily tax controversial." For 2008 Chambers USA Guide added "Charles Rettig of California's Hochman Salkin Rettig Toscher & Perez is regarded by market sources as a 'brilliant and gifted lawyer.'" 
  • Armando Gomez concentrates his practice on a broad range of tax matters. He advises clients on the structuring and financing of domestic and international partnerships and joint ventures, mergers and acquisitions, spin-offs, cross-border transactions and foreign infrastructure projects. Mr. Gomez also represents clients in federal and state tax controversy matters, administrative and policy matters, and on legislative matters.

    An active member of the ABA Section of Taxation, Mr. Gomez is also a frequent lecturer and author on topics relating to partnerships and joint ventures, corporate tax shelters and related controversies and ongoing tax legislative matters.
  • Tom Greenaway works in the Boston office of KPMG’s Tax Controversy Services practice.

    Before joining KPMG, Tom served as a senior attorney in the Large & Midsize Business division of the IRS Office of Chief Counsel. Tom earned his B.A., cum laude, from Columbia College, and his J.D., with honors, from the University of Connecticut School of Law.

    Tom competed as a semi-finalist in the 2002 Law Student Tax Challenge.
  • Adam M. Cohen. Mr. Cohen's practice emphasizes the tax aspects of structuring the formation, acquisition, disposition, operation, and liquidation of businesses, including bankruptcy restructurings, of all sizes in a variety of industries, including manufacturing, health care, retailing, advanced technology, oil and gas, agricultural, finance, and real estate. He provides advice on renewable energy and low-income housing tax credit projects. He has been integrally involved in structuring billion dollar transactions. Mr. Cohen's practice also includes providing advice regarding reportable transactions.

    Mr. Cohen is actively involved in the Tax Section of the ABA, including chairing this group's Task Force on Carried Interests and working with this group to provide comments to the Internal Revenue Service regarding the proper tax treatment of options in the tax partnership setting. He currently serves as the Chair of that Section's Young Lawyers Forum and CLE Coordinator of that Section's Partnerships & LLCs Committee. Mr. Cohen is also actively involved in the Tax Section of the Colorado Bar Association, and is a past Chair of that Section's Executive Council.