Past Competition Winners
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?
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