Katherine M.
Kelleher
ABA GCO GEN-02153
2023.08.29 [Link]
-05'00'
ABA SECTION OF TAXATION
23rd ANNUAL LAW STUDENT TAX CHALLENGE
COMPETITION (2023-2024) OFFICIAL J.D. DIVISION RULES
Part I: Organization of the 2023-2024 Law Student Tax Challenge
1. Purpose and Administration. The Law Student Tax Challenge (the “LSTC”) is an annual inter-law
school transactional planning and client counseling competition.
The Young Lawyers Forum of the American Bar Association Section of Taxation, located at 1050
Connecticut Avenue, NW, Ste. 400 Washington, DC, 20036, sponsors the LSTC. The LSTC is
designed to focus on the tax consequences of hypothetical planning or procedural matters, and is
intended to provide law students with the opportunity to research “real-life” tax law issues and to
demonstrate their acquired tax knowledge, through their writing and oratory skills, in front of the
nation’s largest single group of practicing attorneys, judges, consultants, counsels, and educators
specializing in tax law.
2. The Competition. The competition consists of two parts:
Part 1: Written Work Product (as governed by the rules).
o Problem Release Date: September 1, 2023 released by or before 5pm EST
o Submission Deadline: November 1, 2023 by or before 5pm EST
o Notification of Semifinalists and Finalists: December 5, 2023
Written Work Product includes both (i) a memorandum to a senior partner and (ii) a letter to the client
explaining the contestants’ analysis, conclusions, and recommendations regarding the facts set forth in the
LSTC problem. Both documents must be the original work product of the two student team members.
Part 2: Oral Defense of Written Work Product (“oral defense round”) comprises, as discussed in
more detail below, a semifinalist and finalist round, both of which include defending the Written
Work Product in front of a panel of judges.
o Semifinal and Final Oral Defense Rounds: January 19, 2024 in San
Francisco, California*
* The ABA plans to hold this meeting in person, but reserves the right to cancel or
reschedule this event or convert it to a virtual event if health and safety restrictions
require it. We will update the participants should the plans for this event change.
3. Teams. Any Juris Doctor (J.D.) student team from an ABA-accredited law school (a “Represented
School”) may enter the competition. ABA employees (full- or part-time) and interns are not eligible
to enter the competition.
Each Represented School may enter as many separate teams as it deems appropriate. Each team
must consist of two (2) law students, neither of whom has earned a J.D. degree (or its equivalent)
before the Written Work Product submission deadline date. Past first place winners in the J.D.
division are not permitted to compete in the J.D. division in future years; however, they may
compete in the LL.M. division as J.D. students. 1
Both student team members must be matriculated at an ABA-accredited law school and be in
good standing with such ABA-accredited law school. Both team members must be from the same
school. A student in visiting status will be permitted to participate so long as the student meets at
least one of the following conditions:
a. If the student has matriculated at the Represented School, the student must be a part-time or
full-time student in good standing at the Represented School. No additional disclosure is
required.
b. If the student is in visiting status at the Represented School, the student must be matriculated
at an ABA-accredited law school (the “Home School”), must be a full-time student at the
Represented School, and must be in good standing at the Represented School and the Home
School. The student must also advise the Office of the Dean of the Represented School that
the student will be entering the competition. Finally, the student must complete the following
statement and attach it to the Official Participant Information Form: “[Visiting student’s
name] is in visiting status at [Represented School], is matriculated at [Home School], and has
fully complied with the rules applicable to law students in visiting status.” The student will be
considered a representative of the Represented School for all purposes, although an attempt
will be made to recognize the Home School in applicable press releases.
Students entering the J.D. division who are enrolled in joint degree programs (J.D./LL.M.) may
participate in the J.D. division ONLY IF both of the following conditions are satisfied:
1) The J.D./LL.M. student has not completed all degree requirements for his or her J.D.
degree by the submission due date. If the student has completed all requirements for
his or her J.D. degree, but has yet to receive his or her degree, then this condition is
not satisfied.
2) The J.D./LL.M. student discloses in writing at the time of submitting his or her
team’s entry that he or she has not completed the J.D. degree requirements.
When in doubt as to whether J.D. degree requirements have been satisfied, it is the student’s
responsibility to ensure that he or she has not been conferred a J.D. degree prior to submission of an
entry for the J.D. division. As part of this inquiry (but by no means the exclusive inquiry), a student
should inquire if, on the submission date, the student would be certified by his or her law school as
having completed the requirements necessary to sit for the bar exam in the jurisdiction in which his or
her law school is located. Any evidence of a changed or altered student record with respect to J.D.
credits or degree conferral will result in a disqualification of all team members and may result in further
disqualification of the sponsoring school, if inquiry warrants. J.D. students, whether or not they are
pursuing a joint degree, may compete in the LL.M. division. However, students may not compete in
both the J.D. division and LL.M. division in the same year.
Each team must designate one of its team members as “captain” and all official actions and statements
made by the members of the Young Lawyers Forum administering the LSTC (the “LSTC
Administrators”) will be directed to the captain.
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Each team may have a faculty sponsor (either a faculty member or an attorney approved by the school)
to provide general guidance during the Written Work Product portion of the LSTC, and general
guidance, support and counseling during the Oral Defense portion of the LSTC if its team is selected as
a semifinalist. See Part V: Rules for the Faculty Sponsor.
Each team entering the LSTC will be assigned a competition number, which will be used for
identification purposes as further described herein.
4. Prizes. Prizes include, inter alia, recognition through certificates of participation, plaques or trophies
(“plaques”), and monetary awards, as described more fully below. To be eligible to receive
monetary awards, and certain other prizes, team members are required to provide personal
information as requested by the ABA Section of Taxation. Failure by a team member to provide
requested personal information will result in the forfeiture of such team member’s monetary award
or other prize in connection with the information that was requested. All monetary awards shall be
paid in U.S. Dollars. All winners of awards and prizes will be announced at the ABA Section of
Taxation Midyear Tax Meeting.
a. All student team members who submit Written Work Product as entries for the LSTC will receive
certificates of participation following the conclusion of the ABA Section of Taxation Midyear Tax
Meeting. Student team members submitting Written Work Product will also receive free
membership in the American Bar Association Section of Taxation for the 2023-2024 membership
year. Free Section of Taxation membership requires membership in the American Bar
Association. Students are responsible for paying their ABA membership dues.
b. Each student member of the team submitting the best Written Work Product will receive a
plaque recognizing the accomplishment and a monetary award of two hundred fifty dollars
($250). In addition, a plaque will be presented to the law school.
c. All student team members and faculty sponsors of those teams selected as semi-finalists will
receive complimentary registration to the ABA Section of Taxation Midyear Tax Meeting.
d. All student members of those teams selected as semi-finalists will receive a plaque recognizing
the accomplishment. (The teams awarded the first, second and third place prizes will receive an
additional plaque).
e. Each student member of the third pla ce team will receive a monetary award of two hundred
dollars ($200), free membership in the ABA Section of Taxation for one (1) year after graduation
and free meeting registration for ABA Section of Taxation meetings for one (1) year after
graduation, beginning September 1 following graduation. (Free Section membership and meeting
registration requires membership in the ABA). In addition, a plaque will be presented to the law
school.
f. Each student member of the second pla ce team will receive a monetary award of three
hundred dollars ($300), free membership in the ABA Section of Taxation for two (2) years after
graduation and free meeting registration for ABA Section of Taxation meetings for two (2) years
after graduation, beginning September 1 following graduation. Free Section of Taxation
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membership and meeting registration requires membership in the ABA. In addition, a plaque will
be presented to the law school.
g. Each student member of the first pla ce team will receive a monetary award of five hundred
dollars ($500), free membership in the ABA Section of Taxation for three (3) years after
graduation and free meeting registration for ABA Section of Taxation meetings for three (3)
years after graduation, beginning September 1 following graduation. Free Section of Taxation
membership and meeting registration requires membership in the ABA. In addition, a plaque will
be presented to the law school.
h. Winners are responsible for all taxes associated with the fair market value of prizes. The
American Bar Association will report any prize with a fair market value equal to or greater than
six hundred dollars ($600) to the IRS on Form 1099. The American Bar Association requires
prize winners to execute an affidavit of eligibility, publicity release (except where prohibited),
liability waiver, and IRS Form W-9 prior to the delivery of any prize.
i. Team members will be presented with their awards at a Reception during the Section of
Taxation Midyear Tax Meeting.
j. The American Bar Association makes no warranties with regard to the prizes. Prizes are non-
transferable and winners have no right of substitution.
5. Questions or Comments. All questions or comments concerning the problem, rules, or any
other aspect of the LSTC, should be sent to the contest Administrator, Jennifer Phillips via
email to [Link]@[Link].
Any questions or comments that might impact competitors will be universally communicated
via the official ABA Section of Taxation LSTC website:
[Link]
6. Updates to Rules or Problem. Addenda to the rules or to the problem may be posted from time
to time on the Law Student Tax Challenge website. Competitors should check the Law Student
Tax Challenge website at least weekly for additional information and or updates.
Part II: Rules for the Written Work Product Part of the Competition.
1. Submission Deadline. All written submissions must be received by the ABA Section of Taxation
electronically on or before the designated deadline.
(1) What is Required. Each team must prepare both (i) a memorandum to a senior partner
and (ii) a letter to the client explaining the team’s analysis, conclusions, and recommendations
regarding the facts set forth in the LSTC problem. Both documents must be the original
work product of the two student team members, and must comply with all of the rules
contained herein. Further, one (1) “Official Participant Submission” (available on the LSTC
website) from each team member must be submitted via the link on the LSTC website and
must be received by the deadline stated above. Both team members must submit and sign
separate submissions. Failure to provide contact information (telephone numbers and e-mail
addresses) may delay notification of semi-finalist status.
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The Official Submission includes a release authorizing the
American Bar Association to publish written submissions, in whole or in part.
All entries must be submitted Wednesday, November 1, 2023 by or before 5pm EST in the
following manner: Go to the LSTC website to access the Official Submission link:
[Link]
The designated Team Captain should submit the team’s memorandum and client letter as one file (PDF
format ONLY with the memorandum first followed by the client letter) and name the file as follows –
23rd Annual LSTC– JD WORK PRODUCT – LASTNAME – TEAM CAPTAIN (For example:
23rd Annual LSTC-JD WORKPRODUCT-SMITH-TEAM CAPTAIN) using the survey link
provided on the LSTC homepage. Do not include any names or other identifiers within the body of
the memorandum and client letter. ANY SUBMISSIONS WITH NAMES OR OTHER
IDENTIFIERS WITHIN THE BODY OF THE MEMORANDUM AND OR CLIENT
LETTER WILL BE DISQUALIFIED AND NOT ACCEPTED.
All submissions must be received by the deadline. No entries will be accepted by mail or
facsimile. If you have any difficulty, please call 202-662-8670 or email
[Link]@[Link] by 5PM EST on Wednesday, November 14, 2023.
2. The Memorandum to the Senior Partner.
THE NAME OF THE SCHOOL AND THE NAMES OF THE TEAM MEMBERS
MUST NOT APPEAR ANYWH ERE WITH IN THE MEMORANDUM.
a. Length, font, margins, required heading for the Memorandum and other general requirements: The
Memorandum to the Senior Partner must not exceed 10 pages. Each page must be standard
white letter paper (i.e., 81/2” x 11”), typed using standard Times New Roman 12-point font,
normal character and word spacing, double-spaced lines, and 1” margins at the top, bottom,
right, and left. Nothing other than page numbers may appear in the margins of any page.
Headnotes, footnotes, and endnotes are prohibited.
All statements of law contained in the Memorandum must be properly cited in accordance
with the form prescribed in The Bluebook: A Uniform System of Citation (20th Edition).
Citations must follow the statement in the ordinary text of the Memorandum. The
Heading on the first page of the Memorandum MUST read:
MEMORANDUM
TO: Senior Partner
FROM: J.D. Team Number (leave blank)
DATE ___________
SUBJECT: 2023-2024 Law Student Tax Challenge Problem
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b. Contents of the Memorandum. The Memorandum shall fully set forth the team’s analysis,
conclusion(s) and recommendation(s) with regard to the facts contained in the LSTC
problem. It may be organized in any manner that allows the team to convey its acquired tax
knowledge, and any aesthetic tools (like bolding, underlining, italicizing, bulleting, or
numbering, but excluding headnotes, footnotes and endnotes) are allowed. The facts of the
problem do not necessarily need to be restated in the Memorandum, but the team is free to
incorporate any facts in any way that it thinks are appropriate.
c. Scoring the Memorandum: The maximum score for the Memorandum is 100 points.
i. The style of the Memorandum is worth 10 points. Style includes, but is not limited
to, grammar, spelling, accurate citations, lack of typographical errors, and word
choice.
ii. The organization of the Memorandum is worth 20 points. Organization includes,
but is not limited to, conciseness, ease of readability, the use of headings and
subheadings, the chronology of the discussion, and the proper use of introductory
and transitory sentences and paragraphs.
iii. The content of the Memorandum is worth 70 points. Content includes, but is not
limited to, the logical reasoning and technical accuracy contained in the analysis,
conclusion(s) and recommendation(s) set forth therein, and the use of statutes,
regulations, case law, and other authority in support thereof.
3. The Client Letter.
THE NAME OF THE SCHOOL AND THE NAMES OF THE TEAM
M EM B ER S M UST NOT APPEAR ANYWH ERE WIT H IN T H E
CLIENT LETTER.
a. Length, font, margins and required heading for the Client Letter: The Client Letter must not exceed 5
pages. Each page must be standard white letter paper (i.e., 81/2” x 11”), typed using standard
Times New Roman 12-point font, normal character and word spacing, double-spaced lines,
and 1” margins at the top, bottom, right, and left. Nothing other than page numbers may
appear in the margins of any page. Headnotes, footnotes, and endnotes are prohibited.
The return address on the first page of the Client Letter MUST read:
LAW OFFICES OF J.D. TEAM NUMBER (leave
blank) Tax Town, ABA State, 10000
The client address on the first page of the Client Letter must read:
Client
Tax Town, ABA State, 10000
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The subject line of the first page of the Client Letter must read:
2023-2024 Law Student Tax Challenge Problem
The signature line on the final page of the client letter must read
(without any actual signature):
Sincerely,
J.D. TEAM NUMBER (leave blank)
b. Contents of the Client Letter. The Client Letter shall fully set forth, in layperson’s terms, the
team’s analysis, conclusion(s), and recommendation(s) with regard to the facts contained
in the LSTC problem. The use of any citations to statutes, regulations, case law, or other
authority should be minimized and only included in the letter if absolutely necessary.
c. Scoring the Client Letter: The maximum score for the Client Letter is 60 points.
1. The style of the letter is worth 10 points. Style includes, but is not limited to,
grammar, spelling, lack of typographical errors, and word choice.
2. The organization of the letter is worth 10 points. Organization includes, but is not
limited to, conciseness, ease of readability, the chronology of the discussion, and the
proper use of introductory and transitory sentences and paragraphs.
3. The content of the letter is worth 40 points. Content includes, but is not limited to,
the use of “plain English” (or layperson’s terms) to convey complicated tax
concepts, and the logical reasoning and technical accuracy contained in the analysis,
conclusion(s), and recommendation(s) set forth therein.
4. Judging the Written Work Product.
The LSTC Administrators charged with judging the written work product will determine which teams
are semi-finalists based on the aggregate scores of each team’s memorandum and client letter. The
LSTC Administrators will also determine the best Written Work Product and the second best Written
Work Product. The written round judges will evaluate all of the written submissions received by the
designated deadline based on a standard list of objective criteria as well as content and style (as detailed
above). Team scores – including the judges’ notes – and team rankings will not be released to the
general public, the law schools, or to individual teams either at the Midyear Tax Meeting or after the
conclusion of the LSTC competition.
The LSTC Administrators charged with judging the written work product may, for violations of the
rules, assess a scoring penalty of up to 20 points against a team, or for egregious violations, such as
plagiarism, may disqualify a team. Other examples of violations by a team that may be grounds for a
scoring penalty or disqualification include: failure to complete the Official Participant Information form;
any font size, font type, word, or line spacing violations; use of footnotes or endnotes; failure to use
required headings; and any other violations that would make unfair the comparison of the team’s
submission to the submissions of teams that have complied with the rules. The LSTC Administrators
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also may report ethical violations, including plagiarism, to the appropriate academic or bar admission
authorities. Any decision of the LSTC Administrators is final.
5. Use of Artificial Intelligence
The ABA prohibits the use of all generative artificial intelligence, including large language models, to create
any portion of a contestant’s written submission for this competition whether in the research, writing, or
editing phase. Generative artificial intelligence in this context includes, but is not limited to, OpenAI’s
“GPT” series, BLOOM, Jasper, BERT, Galactica, and Lex (“AI”). Upon submission of the work product,
contestants must affirm that they did not utilize AI in the preparation of their written work product. The
ABA reserves the right to screen submissions for use of AI through an AI detector. Contestants utilizing
AI to generate their work product in whole or in part will be disqualified. Note that for these purposes, AI
does not include basic tools for checking grammar, spelling, references, etc.
Part III: Rules for the Oral Defense Part of the Competition.
1. General Information. At the designated time during the Section of Taxation Midyear Tax Meeting each
of the six (6) teams selected as semi-finalists must orally explain and defend their Memorandum in
front of three (3) to five (5) judges acting as mock senior partners and/or clients (i.e., the semi-final
round). Those semi-finalists who advance to the final round must orally explain and defend their
Client Letter in front of three (3) to five (5) judges acting as mock senior partners and/or clients
(i.e., the final round). Substitution of a team member for the oral competition may be permitted
at the sole discretion of the LSTC Administrators.1
Each semi-finalist team will be required to sign an Oral Defense Compliance Certification Form
before or during the Midyear Tax Meeting (will be sent to the participants directly).
Each team’s oral presentation will be scored based on a standard list of objective criteria as well as
on content and style (as detailed herein). The LSTC Administrators will determine which teams are
finalists, and which teams are awarded third, second, and first place, based on the scores of each
team’s oral presentation. The LSTC Administrators will also make final determinations in the event
of a tie. See Part III: Tie Breaking below.
The LSTC Administrators reserve the right to make adjustments to the Competition, in its sole
discretion, that it deems necessary, including holding the Oral Defense Part of the Competition
virtually, via Zoom or a similar virtual platform.
2. Semi-final Round.
a. Participation. Six (6) teams selected by the LSTC Administrators as semi-
finalists will be invited to the ABA Section of Taxation Midyear Tax
Meeting to compete in the semi-final round. All six semi-finalist teams will compete
on the Friday of the meeting, at the time and location and in the order to be determined and
communicated to each team onsite during the meeting.
b. Grouping of semi-finalist teams. The semi-finalist teams will be divided into two groups. Each group
will appear before a different panel of judges. The two semi-finalist teams having the highest
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scores on the Written Work Product will be placed in separate groups. Each remaining semi-
finalist team will be randomly assigned to a group. Neither the semi-finalist teams nor the judging
panels will be advised of the teams’ scores or relative rankings on the Written Work Product. The
team with the highest score on the Written Work Product will be announced at a Reception
during the Midyear Tax Meeting.
1 Ifyou need an accommodation, please contact the ABA. The ABA will make reasonable accommodations in compliance with
the Americans with Disabilities Act.
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c. Attendance. The semi-final round will be open to the general public. However, team faculty
sponsors for J.D. teams participating in the semi-final round and/or for LL.M. teams
participating in oral defense are prohibited from attending the semi-final round for any teams
other than the faculty sponsor’s own team(s). Participants may not watch other teams or gather
information regarding the performance of another team (or of the judges) either directly or
indirectly during the semi-final rounds. Participants may not communicate with anyone about the
performance of other teams until after the competition ends.
d. Concept and purpose of semi-final round. In the semi-final round, the judges will act as the “senior
partners in the law firm” and/or “clients,” and the teams will act as the “associates.” Each of the
six semi-finalist teams will, individually, appear before the judges. Each team will be judged on the
understanding and communication of the team members’ collective tax knowledge regarding the
problem. Each team will be expected to explain and defend its Written Work Product, but the
judges are not prohibited from asking questions to any particular team that are not addressed in
their respective Written Work Product. Note further that semi-final round judges will not have
reviewed any team’s Written Work Product.
e. Length of questioning and how the team should start. Each team will appear for 25 minutes in front of
the judges. Both team members must be present. While each team member is expected to
participate in the semi-final round, the actual division of responsibilities and oration rests solely
on each team. However, as noted, part of the scoring represents the active participation of both
team members.
The team’s only introduction should be their competition team number and their first names.
Each team should start by setting forth their overall analysis, conclusion(s) and
recommendation(s) to the problem, and state any unresolved issues and/or additional
information that is needed from the client. The judges, whether acting as senior partners or
clients, are free to ask questions at any time. The students will be judged on how well they
answer such questions and how thoroughly and concisely they explain their analysis,
conclusion(s), and recommendation(s) (both on an individual basis and collectively as a team).
f. Materials needed for the semi-final round. The team members are allowed to bring a copy of the
Internal Revenue Code and any other written material to their semi-final round and are free to
use such materials as needed. Team members may provide visual aids in the form of hand outs,
provided that such hand outs shall not exceed the maximum dimensions (width and height) of
81/2” x 11.” A minimum of six (6) identical copies of the semi-final round hand outs shall be
submitted by the team to the LSTC Administrators immediately prior to the team’s appearance
in the semi-final round. No other visual aids of any kind shall be permitted. Team members are
encouraged to consider the appropriateness of using visual aids in a presentation to a senior
partner or client. Points will not be awarded for the use of visual aids.
g. Scoring the semi-final round. The maximum score for each team is 30 points.
1. The teamwork shown during the semi-final round is worth a total of 5 points. Teamwork
includes, but is not limited to, the effectiveness of the team members in dividing their
participation, the level of respect that each team member shows toward the other, and the
level of knowledge regarding the facts and the tax law collectively demonstrated by the
team.
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2. The technical tax knowledge demonstrated during the semi-final round is worth a total of 15
points (7.5 points for each team member). Technical tax knowledge includes, but is not
limited to, setting forth an accurate technical analysis of the problem, providing accurate
responses to questions, understanding technical questions and applying the Federal tax law
to related issues, understanding the scope and potential consequences of the problem and
related Federal tax law issues, and substantiating responses with accurate references to legal
authorities when appropriate.
3. The individual presentation during the semi-final round is worth a total of 10 points (5 points
for each team member). Individual presentation includes, but is not limited to, familiarity with
the facts of the problem, poise, persuasiveness, demeanor, clarity of responses, proper use of
the English language, and overall effectiveness. Particular attention is given to how the
students tailor their presentations to the audience (senior partners and/or clients).
3. Final Round.
a. Participation. Three (3) teams selected by the LSTC Administrators as
finalists will participate in the Final Round. The highest-scoring team
from each group and the highest-scoring team of the remaining four semi-finalist
teams will be selected as finalists. All three finalist teams will compete on the Friday
afternoon of the Midyear Tax Meeting.
b. Attendance. The final round will be open to the general public. However, team
faculty sponsors for J.D. teams participating in the final round and/or LL.M. teams
participating in oral defense are prohibited from attending the final round for any
teams other than the faculty sponsor’s own team(s). Participants may not watch
other teams or gather information regarding the performance of another team (or
of the judges) either directly or indirectly during the final rounds. Participants may
not communicate with anyone about the performance of other teams until after the
competition ends.
c. Concept and purpose of final round. In the final round, the judges will act as the “senior
partners in the law firm” and/or “clients,” and the teams will act as the “associates.”
Each of the three finalist teams will, individually, appear before the judges. Each
team will be aggregately judged on the understanding and communication of the
team members’ collective tax knowledge regarding the problem. Each team will be
expected to explain and defend its Client Letter, but the judges are not prohibited
from asking questions to any particular team that are not addressed in their
respective Written Work Product.
d. Length of questioning and how the team should start. Each team will appear for 25 minutes in
front of the judges. Both team members must be present. While each team member is
expected to participate in the final round, the actual division of responsibilities and
oration rests solely within each team. However, as noted, part of the scoring
represents the active participation of both team members.
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The team’s only introduction should be their competition team number and their
first names. Each team should start by setting forth, in layperson’s terms, their
overall analysis, conclusion(s) and recommendation(s) to the problem, and state any
unresolved issues and/or additional information that is needed from the client. The
judges (acting as non-attorney clients) are free to ask questions at any time. The
students will be judged on how well they answer such questions and how thoroughly
and concisely they explain their analysis, conclusion(s), and recommendation(s) (both
on an individual basis and collectively as a team).
e. Materials needed for the final round. The team members are allowed to bring a copy of
the Internal Revenue Code and any other written material to their final round and
are free to use them as needed. Team members may provide visual aids in the form
of hand outs, provided that such hand outs shall not exceed the maximum
dimensions (width and height) of 81/2” x 11.” A minimum of six (6) identical copies
of the final round hand outs shall be submitted by the team to the LSTC
Administrators immediately prior to the team’s appearance in the final round. No
other visual aids of any kind shall be permitted. The team members are encouraged
to consider the appropriateness of using visual aids in a presentation to a client.
Points will not be awarded for the use of visual aids.
f. Scoring the final round: The maximum score for each team is 30 points.
i. The teamwork shown during the final round is worth a total of 5 points.
Teamwork includes, but is not limited to, the effectiveness of the team
members in dividing their participation, the level of respect that each team
member shows toward the other, and the level of knowledge regarding the
facts and the law collectively demonstrated by the team.
ii. The technical tax knowledge demonstrated during the final round is worth a
total of 15 points (7.5 points for each team member). Technical tax
knowledge includes, but is not limited to, setting forth accurate technical
analysis of the problem, providing accurate responses to questions,
understanding technical questions and applying the Federal tax law to related
issues, understanding the scope and potential consequences of the problem
and related Federal tax law issues, and substantiating responses with
accurate references to legal authorities when appropriate.
iii. The individual presentation during the final round is worth a total of 10
points (5 points for each team member). Individual presentation includes,
but is not limited to, familiarity with the facts of the problem, poise,
persuasiveness, demeanor, clarity of responses, proper use of the English
language, and overall effectiveness. Particular attention is given to how the
students tailor their presentations to the audience (senior partners and/or
clients).
iv. Tie-Breaking. If, in scoring any round, any tie occurs among teams, then the
following tie-breakers shall be used: (i) the team having the highest “individual
presentation” score for the round; and next, (ii) the team having the highest score on
the Written Work Product.
Part IV: Rules for the Law Student Team Members.
1. Written Work Product. Each team member must sign a declaration on the Official Participant
Information form that only the two law student team members have researched the problem and
prepared the Written Work Product (which consists of the Memorandum and the Client Letter).
The team members themselves are the only individuals allowed to research, draft, proofread, and
edit their Written Work Product. The students are free to research any information available to
the public, including any primary and secondary resources whether available by subscription or
not, but may not have individual discussions with other students, attorneys, professors, or tax
professionals about the problem, other than general discussions with the faculty sponsor.
2. Oral Defense of Written Work Product. The students are encouraged to practice their oral
presentations before the competition. However, the roles of any other student, attorney, professor,
or tax professional acting as a mock judge must be limited to asking questions, indicating whether
the responses were generally correct or not, and generally where the students can conduct further
research if incorrect responses were given. The mock judges at the practices are free to offer advice
on the oratory and presentation skills of the student team members. The members of each semi-
finalist team will be required to sign a compliance form prior to the commencement of the semi-
final round.
Part V: Rules for the Faculty Sponsor.
1. Written Work Product. The faculty sponsor may instruct the student team members on proper
research techniques and provide general advice. By way of illustration, directing student team
members to a particular Internal Revenue Code section is permitted general advice. Directing
students to cases, regulations, administrative materials, or secondary sources is not general advice,
and is forbidden. The faculty coach may say “I direct you to Sections X, X, and X” but not “It
looks like the problem is raising a XXXX issue; you should look at Section X, which talks about
XXXX.” The faculty sponsor may also comment on the proper structure of a Memorandum and
Client Letter, but may not help to draft, proofread, or edit the Written Work Product of the
student team members.
2. The Oral Defense of the Written Work Product. The faculty sponsor may arrange practice sessions in
front of other students, professors, attorneys, or tax professionals (including the faculty sponsor) that
are structured to improve the students’ individual oratory and presentation skills, their demonstrated
teamwork, and the discovery of holes in arguments or incorrect statements. However, the faculty
sponsor must ensure that no one acting as a mock judge provides the students with anything
more than general advice and comments.
Part VI: Additional Terms and Conditions.
1. The American Bar Association is not responsible for any computer or software errors,
Internet failures, misdirected emails, printing errors in these rules, or other technical failures
incurred by contestants.
2. By entering, each contestant consents to the publication of her/his entry by the ABA,
understands that such publication is not guaranteed, and grants the ABA the right of
publication and the non-exclusive, perpetual right to publish the work in its periodicals,
books, anthologies, ebooks, audiobooks, website, or any other publication platform, whether
print or digital without further compensation. Any contestant, whose work is chosen for
publication, must sign a separate publication agreement, giving the ABA publication rights
enumerated in these Official Rules and the right to use the written submission for any
purpose related to the ABA mission. If the winner(s) fail to sign the agreement within 60 days
of receipt, the prize will be considered forfeited and another winner named.
3. By entering, the winners agree to allow the use of their names, photographs, likenesses, and
biographical information for advertising, publicity, and promotional purpose in all media without
compensation.
4. The Competition is subject to all federal, state, and local laws and regulations. By entering, all
participants agree that the Competition shall be governed by the laws of the State of Illinois, that
the courts of Illinois shall have exclusive jurisdiction, and that Cook County, Illinois shall be the
venue for any dispute or litigation relating to or arising from the competition. Void where
prohibited.
5. The American Bar Association reserves the right not to award any prize if the judges determine that
no entries are of sufficient quality to merit selection.
6. By participating, each contestant agrees to these Official Rules and the decisions of the ABA. Each
contestant hereby releases the American Bar Association and its respective employees, officers,
directors, contractors, agents, representatives, successors and assigns from any damage, loss, or
other liability that may arise from or in any way relate to participation in this contest. This contest
will be governed by all federal, state, local and municipal laws and regulations. This contest is void
where prohibited by law. Any claim, judgment, or award will be limited to a contestant’s actual out-
of-pocket costs associated with entering this contest. Contestant hereby waives any right or claim to
attorney's fees, indirect, special, punitive, incidental, or consequential damage.
7. Opt-Out Option: Any individual may elect to opt out of receiving future contest or competition
mailings from the ABA by calling the ABA Service Center at 800-285-2221.
8. Information provided by entrants in connection with this contest is subject to the American Bar
Association’s privacy policy available at [Link]
