The Theodore Tannenwald Jr.

Foundation for Excellence

in Tax Scholarship

                                 

Competition Winners


2016

First Prize $5,000:
Jesse Boretsky
Yale Law School
Redefining a Blurry Line: A Proposal to Reform the Taxation of Pension Fund Business and Investment Income
Faculty Sponsor:  Prof. Yair Listokin

Second Prize (tie, $2,000):
Sam Lapin
Temple University Beasley School of Law
Finding Propaganda: How to Stop Grassroots Lobbying Costs From Slipping Through the Cracks of Section 162(e)
Faculty Sponsor:  Prof. Alice Abreu

Matthew Swift
The University of Chicago Law School
Between a Rock and a Hard Place:  Evaluating the Illinois Retirement Income Exemption
Faculty Sponsor:  Prof. Daniel Hemel

2015

First Prize $5,000:
Sienna White
Notre Dame Law School
Cost Sharing Agreements & the Arm’s Length Standard: A Matter of Statutory Interpretation?
Faculty Sponsor:  Prof. Lloyd H. Mayer

Second Prize $2,500:
Joseph C. Dugan
Indiana University Maurer School of Law
Compromising Compliance?
The IRS Offer in Compromise Program and Opportunities for Reform
Faculty Sponsor:  Prof. Leandra Lederman

Third Prize $1,500:
Steven Ort
University of Texas at Austin School of Law
Tracing Time: How Inversion Transactions Change But Remain Undeterred
Faculty Sponsor:  Prof. Calvin Johnson

Honorable Mention:
Carson W. King
University of Illinois College of Law
When Virtual Reality Becomes Real: Taxation of CryptoCurrencies
Faculty Sponsor:  Prof. Richard L. Kaplan

2014

The 2014 Competition results are set forth below (no second or third prize awarded):

First Prize (Tie - $4,500 each):
Alex Levy
New York University School of Law
Believing in Life After Loving: IRS Regulation of Tax Preparers
Faculty Sponsor:  Prof. David Kamin

Mark C. Westenberger
Washington University in St. Louis School of Law
Tax-Exempt Hospitals and the Community Benefit Standard:
A Flawed Standard and a Way Forward

Faculty Sponsor:  Prof. Cheryl D. Block

Honorable Mentions:
Nika Antonikova
University of San Diego
Real Taxes in Virtual Economies: What Does the I.R.S. Say
Faculty Sponsor:  Brian Galle

Michael Daly
Georgetown University Law Center
Bound and Gagged: Making the Case for Congress Delegating Tax Policy to the Experts
Faculty Sponsor:  Tom Field

2013

First Prize (Tie - $3,750 each):
Kate B. Deal
Georgetown University Law Center
Incentivizing Conservation: Capping Land Trusts' Acceptance of Tax-Preferred Easements to Maximize Overall Conservation Value
Faculty Sponsor: Prof. Ronald A. Pearlman

Franziska Hertal
Columbia Law School
Qui Tam for Tax? Lessons from the States
Faculty Sponsor: Prof. Alex Raskolnikov

Third Prize ($1,500):
Beomjune Kim
New York University School of Law
Reconciling Transfer Pricing with Customs Valuation: How to Bridge the Gap?
Faculty Sponsor: Prof. H. David Rosenbloom

Honorable Mentions:
William G. Cochran
Stanford Law School
Searching for Diamond in the Two-and-Twenty Rough: The Taxation of Carried Interests
Prof. Joseph Bankman

Alex Goodenough
Georgetown University Law Center
Commensurate With Income and the Arm's Length Standard: The Problem of Pricing Intangibles
Prof. David Ernick

2012

First Prize ($5,000):
Christopher R. Wray
University of Notre Dame Law School
On the Road Again: The D.C. Circuit Reinvigorates The Work-Product Doctrine in United States v. Deloitte & Touche
Faculty Sponsor:  Prof. Matthew J. Barrett

Second Prize ($2,500):
Philip Sancilio
Columbia Law School
Clarifying (or Is It Codifying?) the “Notably Abstruse:”  Step Transactions, Economic Substance, and the Tax Code
Faculty Sponsor:  Prof. Alex Raskolnikov

Third Prize ($1,500):
Frank Fagan
University of Pittsburgh School of Law
The Growing Problem with Temporary Provisions in the Tax Code: Not Rent-seeking, Not Investment Uncertainty, But Reelection Strategy
Faculty Sponsor:  Prof. David J. Herring

2011

First Prize ($5,000):
Michael Behrens
UCLA School of Law
Citizens United, Tax Policy, and Corporate Governance
Faculty Sponsor:  Prof. Steven Bank

Second Prize (tie) ($2,000):
Jacob Dean
University of Cincinnati College of Law
“Do you have that new church app for your iPhone?”  Making the Case for a Clearer and Broader Definition of Church Under the Internal Revenue Code
Faculty Sponsor:  Prof. Stephanie Hunter McMahon

Second Prize (tie) ($2,000):
Stas Getmanenko
Southern Methodist University School of Law
Consequences of Carried Interest Reform for the Private Investment Industry
Faculty Sponsor:  Prof. Christopher Hanna

Honorable Mentions:
Tessa Davis
Florida State University College of Law
Reproducing Value
Faculty Sponsor:  Prof. Curtis Bridgeman

Jacob Goldin
Yale Law School
Libertarian Paternalist Meets Tax Policy:  Designing Commodity Taxes for Inattentive Consumers
Faculty Sponsor:  Prof. Yair Listokin

2010

First Prize ($5,000):
Caroline Waldner
New York University School of Law
In Defense of College Savings Plans:  Using 529 Plans to Increase the Impact of Direct Federal Grants for Higher Education to Low- and Moderate- Income Students
Faculty Sponsor:  Prof. Lily Batchelder

Second Prize (tie) ($2,000):
Frederick N. Vinson
University of Florida Levin College of Law
Taxation of Unhedged Financial Derivatives Transactions:  The Need for Schedularization
Faculty Sponsor:  Prof. Martin J. McMahon, Jr.

Second Prize (tie) ($2,000):
Timothy Hisao Shapiro
Stanford Law School
Tax First, Ask Questions Later:  Problems Predicting the Effect of Obama’s International Tax Reforms
Faculty Sponsor:  Prof. Joseph Bankman

Honorable Mention:
Brian Demeter
Cleveland-Marshall College of Law
Cleveland State University
Faxing the Backstop:  Alleviating Pressure on Transfer Pricing of Intangibles by Amending Subpart F
Faculty Sponsor:  Prof. Deborah A. Geier

2009

First Place
David J. Warner
New York University School of Law
Sponsor:  Prof. Noël B. Cunningham
A Pathway to Fundamental Healthcare Reform?:
The Exclusion from Income for Employer-Sponsored Health Insurance

Second Place
Grace E. Jeon
Northwestern University School of Law
Sponsor:  Prof. Charlotte Crane
Loss Recognition Allowed:  Target Shareholders Can Now Enjoy
Selective Non-Recognition Treatment in Reorganization Exchanges

Third Place
Michael J. Blinn
Indiana University School of Law
Sponsor:  Prof. Ajay Mehrotra
The Behavioral Case for a Value-Added Tax

2008

First Place
Kathryn A. Fuehrmeyer
University of Notre Dame School of Law
Sponsor:  Prof. Lloyd H. Mayer
Cutting Out the Middleman:  Allowing Onshore Debt-Financed Investments by Tax-Exempt Organizations

Second Place
Andrew D. Appleby
Wake Forest University School of Law
Sponsor:  Prof. Joel S. Newman
Ball Busters:  How the IRS Should Tax Record-Setting Baseballs and Other Found Property Under the Treasure Trove Regulation

Third Place
Leslie J. Carter
University of Chicago School of Law
Sponsor:  Prof. Julie Roin
Blowing the Whistle on Avoiding Use Taxes in Online Purchases

2007

First Place
James Bamberg
University of Florida Levin College of law
Sponsor: Prof. Kristin Gutting
A Different Point of Venue:  The Plainer Meaning of Internal Revenue Code Section 7482(b)

Second Place
David Kamin
New York University School of Law
Sponsor: Prof. Lily Batchelder
What's a Progressive Tax Change?  Unmasking Hidden Value in Distributional Debates

Third Place
Joshua R. Mourning
Washington University in St. Louis School of Law
Sponsor: Prof. Cheryl D. Block
A Tax Policy Analysis of Congress's Labyrinthine Stock Option Tax Scheme

Honorable Mentions
Lora Cicconi
UCLA School of Law
Sponsor: Prof. Steve Bank
Blaming 162(m) for the Backdating Scandal:  Legitimate Concerns or Scapegoating?

Michelle Christenson, New York University School of Law
Sponsor: Prof. Lily Batchelder
Optimal Property Taxation:  An Endowment Tax on Land Value

2006

First Place
Manoj Viswanathan
New York University School of Law
Sponsor: Prof. Lily Batchelder
Sunset Provisions in the Tax Code: A Critical Evaluation and Prescriptions for the Future

Second Place
Markus Ernst
New York University School of Law
Sponsor: Prof. H. David Rosenbloom
Toward a Level Playing Field for Thin Capitalization -- A Comparison Between German and U.S. Approaches

Amandeep S. Grewal
Georgetown University Law Center
Sponsor: Prof. Albert G. Lauber, Jr
Substance Over Form? Phantom Regulations and the Internal Revenue Code

Honorable Mentions
Mark Totten
Yale Law School
Sponsor: Prof. Anthony Kronman
The Politics of Faith: Toward Legislative Revisions of the I.R.C. Prohibition on Political Intervention

Lora Cicconi
UCLA School of Law
Sponsor: Prof. Kirk J. Stark
Competing Goals: Amidst the "Opt-Out" Revolution: An Examination of Gender Based Tax Reform in Light of New data on Female Labor Supply

Deanna Joy Green and Julia Conn
Boston University School of Law
Sponsor: Prof. Alan L. Feld
Crafting a Post-CUNO Course for Constitutional State Tax Incentives

2005

First Place
Chloe A. Burnett
New York University School of Law
Sponsor: Prof. H. David Rosenbloom
From the CFC Babel to the Round Table:  Replacing Multiple CFC Regimes With a Collective, Targeted Attribution System

Second Place
Celia Whitaker
Yale Law School
Sponsor: Prof. Michael J. Graetz
How to Build a Bridge:  Eliminating the Book-Tax Accounting Gap

Third Place
Andrew L. Grossman
New York University School of Law
Sponsor: Prof. Deborah Schenk
Examining the Education Provisions of the Tax Code

Honorable Mentions
Lindsay H. Rubel
Washington & Lee School of Law
Sponsor: Prof. Harlan Beckley
Complexity, Regressivity, and Income Disparity:  Self-defeating Aspects of the Earned Income Tax Credit.

Joshua Mishkin
University of Maryland School of Law
Sponsor: Prof. Robert I. Keller
The State of Integration in a Partial Integration  State:  A Discussion of Corporate Tax Integration, President Bush's Fiscal 2004 year Proposals, and The Jobs and Growth Tax  Relief Reconciliation  Act of 2003

Natalya Teplitsky
Hofstra University School of Law
Sponsor:Prof. Linda Galler
Contingent Liability Tax Shelters:  Past, Present and No Future

Chin-Chin Yap (Ms.)
Georgetown University Law Center
Sponsor: Prof. Ethan Yale
The Tax Shelter Games

2004

First Place
Robert Yablon
Yale Law School
Sponsor: Prof. Michael Graetz
Defying Expectations:  State Responses to the Repeal of the State Death Tax Credit

Second Place
Gabriel S. Garcia
UC Berkley - Boalt Hall School of Law
Sponsor: Prof. Eric P. Rakowski
Server Location v. Contention Creation:  An Analysis of Place of Service Rules in International Taxation of E-Commerce

Third Place
Elizabeth Chorvat
University of Virginia School of Law
Sponsor: Prof. Edwin Cohen
A Thinly-veiled Mischief:  The Case Against Tax Harmonization

Rebecca M. Kysar
Yale Law School
In Critique of Sunset Provisions in the Tax Code

Honorable Mentions
Leeanna Izuel
Loyola Law School
Sponsor: Prof. Theodore Seto
Rules vs. Standards:  Revisiting the Dutch Boy's Success

Elena Tsaneva
Brooklyn Law School
Sponsor: Prof. Harry Ballan
Transfer Pricing in the World of Services and Intangibles - A New Challenge to Preserving the Corporate Tax Base

2003

First Place
Sagit Leviner
The University of Michigan School of Law
Sponsor: Prof. Kyle Logue
1. Affordable Housing:  The Role of the Low Income Housing Tax Credit Program -- A Contemporary Assessment
2. The Vision of a Good Society and the Tax System or Tax Justice Revisits

Second Place
Trever Asam
Duke Law School
Sponsor: Prof. Richard Schmalbeck
Bob Jones Goes to Hawaii:  Charitable Institutions, the Mancari Doctrine, and Hawaiians-Only Education at the Kamehameha Schools

Third Place
Mindy Herzfeld
Georgetown University Law Center
Sponsor: Prof. Clarissa Potter
The Intersection of U.S. Tax Policy and U.S. Foreign Policy

Honorable Mentions
Michelle Jewett
Harvard Law School
Sponsor: Prof. Bernard Wolfman
Stock Options Used as Executive Compensation:  Current Tax and Accounting Treatment, Possible Reform, and Congressional Proposals to Align the Two

Alexis A. Olson
University of Florida Fredric G. Levin College of Law
Sponsor: Prof. Martin J. McMahon, Jr
1. Are Subchapter C sections obviated when corporations no longer have an incentive to distribute earnings as capital gains?
2. The effect of the excludable dividend proposal on Subchapter C

2002

First Place
Mark E. Erwin
New York University School of Law
Sponsor: Prof. Linda Sugin
A Policy Analysis and Critique of the Joint Committee on Taxation's Simplification Study

Second Place
Amy Beth Erenrich
Harvard Law School
Sponsor: Alvin C. Warren
The Taxation of Equity-Linked Debt Instruments

Steven Quiring
University of Texas Law School
Sponsor: Prof. Calvin H. Johnson
Section 357(c) and the Elusive Basis of the Issuer's Note

Elena Romanova
New York University School of Law
Sponsor: Prof. Deborah Schenk
Cancellation of Nonmember Indebtedness Within Consolidated Groups:  Implications of United Dominion Indus., Inc. v. U.S.

Honorable Mentions
Delphine G. Pioffret
University of Richmond, T.C. Williams School of Law
Sponsor: Prof. Mary L. Heen
The WTO Appellate Body's Ruling Against U.S. Export-Contingent Tax Subsidies: History of the Dispute, Arguments of the Parties and Consequences of the Decision

Allison E. Wielobob
Georgetown University Law Center
Sponsor: Prof. Clarissa Potter
U.S. and International Taxation of Stock Options – An Overview of the Thorny Issues

Emerson Moser
Wake Forest University School of Law
Sponsor: Prof. Joel S. Newman
The Victims of Terrorism Tax Relief Act of 2001:  How 4 Planes, 4,000 Casualties and 435 Representatives Created a Tax Policy Disaster

2001

First Place
Shawn P. Travis
Harvard Law School
Sponsor: Prof. Alvin C. Warren, Jr.
The Accelerated & Uneconomic Bearing of Tax Burdens By Mutual Fund Shareholders

Second Place
Damian Laurey
University of Virginia
Sponsor: Prof. George K. Yin
Untangling the Stock Option Cost Sharing Loophole

Third Place
Janine Shissler
Yale Law School
Sponsor: Prof. Michael J. Graetz
The Simplification Potential of Adopting an Exemption System for Foreign Source Active Business Income

Honorable Mentions
Annie Ligman
University of San Diego
Sponsor: Prof. Lester B. Snyder
The Tax Treatment of Stock Option Compensation Under the Haig-Simon and Mark-to-Market Theories of Income Measurement

Michael M. Lloyd
University of Maryland
Sponsor: Prof. Daniel S. Goldberg
A Tale of Two Theories:  Should Section 1041 Trump the Assignment of Income Doctrine?

Ruth Mason
Harvard Law School
Sponsor: Prof. Bernard Wolfman
Spinning Section 355(e):  Will Treasury Interpret the Anti-Morris Trust Provision According to Its Purpose?