McIntosh, Pendergraft to Represent Law School in ABA Tax Competition

December 21, 2006
Ballenger family
Jason McIntosh and Sarah Pendergraft will journey to Hollywood, Fla. to compete in the annual competition sponsored by the ABA Tax Section.

Third-year law students Jason McIntosh and Sarah Pendergraft have been selected to compete in the semifinals of the American Bar Association's Law Student Tax Challenge, an alternative to traditional moot court competitions that asks students to solve cutting-edge and complex business problems. Teams from about 40 law schools vied for the six slots; semifinalists will travel to the ABA Tax Section's midyear meeting Jan. 19 in Hollywood, Fla., where they will defend their solution before some of the top tax practitioners in the country.

"It's nice to be able to apply your knowledge you get in law school to a real-world situation. [The faculty] really do a good job of taking the theoretical and kind of dry subject of tax and turning it into an exciting real-world subject in the classroom," McIntosh said. "I felt really well-prepared when I faced a problem like the one they gave us in this competition."

This year's problem involved a merger between two companies; teams had to decide how to structure both the transaction and the executive compensation in accordance with tax regulations and to the maximum benefit of their client. In the first round, contestants submitted a memorandum to a fictional senior partner and a letter to a fictional client explaining their conclusion. In the next phase of the competition, Pendergraft and McIntosh will present their solution and defend it before a panel of judges acting as the senior partner. Later in the day, the field will be winnowed down to three teams who will meet with the "client" to explain their memo.

"It demands two different skills from you-one is your ability to write about very difficult complex topics in a way that's easy to understand, [and the other is] orally presenting at a highly technical level for the senior partner and at a layman level for the clients," McIntosh said.

"It was a challenging problem and we spent a lot of time researching and writing," Pendergraft said. "The best part of the process was working with Professor [Michael] Doran, who has been really helpful."

Doran, who formerly worked in the Office of Tax Policy at the U.S. Treasury Department, encouraged the pair to enter the contest.

"Sarah and Jason are both excellent law students, and they are both going to be top-notch lawyers," said Doran. "From their work in my courses last year, I was confident that they would be able to research and analyze a challenging business tax problem with minimal guidance, which is what the competition requires."

Both Pendergraft, who plans to work for McKee Nelson in Washington, D.C., after graduation, and McIntosh, who plans to work for Vinson & Elkins in Houston, are pursuing careers in tax law.

"What interests me in particular about tax law is how it touches every area of American life," said McIntosh, who majored in engineering at the University of Nebraska. Pendergraft, who majored in political science at the University of North Carolina, analyzed tax policy for Sen. John Edwards on Capitol Hill before coming to law school. "I thought the competition would be a good opportunity to get some practical experience," she said.

Although McIntosh, who handled the executive compensation portion of the problem, never took a class on the subject, he said his tax classes at Virginia gave him the "ability to think through new problems.

"Executive compensation has become even more complex very recently with the addition of some new laws, one of which Professor Doran helped draft," he said.

"We were addressing a completely new issue," added Pendergraft. "The regulations still haven't been finalized, but tax practitioners are having to look ahead [when making today's deals]."

In the past, judges for the semifinal and final rounds have included high-ranking government officials and some of the most accomplished members of the national tax bar, Doran said. In preparation, McIntosh and Pendergraft will practice their presentation with Doran and Professor George Yin, who recently served as chief of staff of the U.S. Congress's Joint Committee on Taxation.

Winners of the competition receive a plaque, a small cash prize, and free membership to the tax section of the ABA for several years.

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