Christopher M. Pietruszkiewicz

Transcription

1 Christopher M. Pietruszkiewicz LSU Law Center Louisiana State University 400E Law Center Building Baton Rouge, Louisiana (225) ACADEMIC EXPERIENCE LSU LAW CENTER, LOUISIANA STATE UNIVERSITY, Baton Rouge, LA (7/01 - Present) Vice Chancellor for Business and Financial Affairs (2008 Present) J.Y. Sanders Professor of Law ( Present) J.Y. Sanders Associate Professor of Law ( ) Assistant Professor of Law ( ) Vice Chancellor for Business and Financial Affairs o Liaison for financial discussions, performance metrics, and curricular matters with University administration, higher education governing boards, legislative leaders, and Governor s Office; alumni and outreach events; strategic planning; allocation of operating and private resources; operating & capital outlay budgeting and planning; comprehensive financial information reporting and analysis; grant and contractual obligations and agreements; internal controls; risk management; personnel; building operations Courses o Income Tax o Corporate Tax o Tax Policy & Procedure Seminar o Tax Practice & Procedure o Accounting for Lawyers o Comparative Tax (Université Jean Moulin, Lyon 3, Lyon, France 2004) Committee Service o Long Range Planning and Self Study Committee (2008 (Chair (Spring)), 2009, 2010 (Chair (Spring)) o Executive Committee (Elected 2002, 2003, 2006, 2007);(ex-officio 2008, 2009, 2010) o Faculty Committee on Scholarship (2008, 2009 (Chair), 2010 (Chair)) o Admissions Committee (2003, 2004, 2005 (Chair), 2006 (Chair), 2007 (Chair)) o Scholarship Committee (2004, 2005 (Chair), 2006 (Chair), 2007 (Chair)) o International Student Programs & LL.M. Program (2009, 2010) o Continuing Legal Education Committee (2009, 2010) o Models for Change Committee (2009) o Clinical Committee (2008) o Library Director Search Committee (2008) o Chancellor Search Committee (2006) o Diversity Task Force (2004, 2005) o Web Design Committee (2004, 2005) o Appointments Committee (2003, 2004) o Information Technology Committee (2004)

2 PAGE 2 o Ad Hoc Disciplinary Committee (2002, 2004 (Chair)) o Graduate & International Programs Committee (2002) o Faculty Seminars Committee (2002) Other Service o Established and Supervise Externship Program with United States Department of Justice o Established and Supervise Externship Program with Internal Revenue Service, Office of Chief Counsel o Established and Supervise Externship Program with Louisiana Department of Revenue o Coach National Tax Moot Court Team o Coach ABA Tax Section Law Student Challenge GEORGE MASON UNIVERSITY SCHOOL OF LAW, Arlington, VA (8/00-12/00) Adjunct Professor of Law Corporate Tax TREATISES/HORNBOOKS Corporate Reorganizations (CCH), with Roberta F. Mann and Jonathan R. Flora (2006) Mastering Income Tax (Carolina Academic Press), with Gail L. Richmond (Work in Progress) LAW REVIEW PUBLICATIONS Terrorism, Communism, and the Internal Revenue Code Work in Progress Economic Substance and the Standard of Review 60 ALABAMA LAW REVIEW 339 (2009) Conflating Standards of Review in the Tax Court: A Lesson in Ambiguity 44 HOUSTON LAW REVIEW 1337 (2007) Discarded Deference: Judicial Independence in Informal Agency Guidance 73 TENNESSEE LAW REVIEW 1 (2006) Does the Internal Revenue Service Have a Duty to Treat Similarly Situated Taxpayers Similarly? 74 UNIVERSITY OF CINCINNATI LAW REVIEW 531 (2005) Of Summonses, Required Records, and Artificial Entities: Liberating the IRS from Itself 73 MISSISSIPPI LAW JOURNAL 921 (2004) A Constitutional Cause of Action and the Internal Revenue Code: Can You Shoot (Sue) the Messenger? 54 SYRACUSE LAW REVIEW 1 (2004) Noncontrolled Section 902 Corporation: Playing Field Leveled by TRA >97 U.S. TAXATION OF INTERNATIONAL OPERATIONS &6001 (August 1998) The Taming of the Noncontrolled Section 902 Corporation Provisions: A Step Toward Subpart F 15 JOURNAL OF TAXATION OF INVESTMENTS 257 (1998)

3 PAGE 3 SELECTED PROFESSIONAL PRESENTATIONS Administrative and Litigation Issues in Innocent Spouse Cases (Panel), American Bar Association, Section of Taxation, Fall Meeting, Toronto, Canada (September 2010) United States Supreme Court and Legislative Update: Corporate, Civil Litigation, Business, Administrative, and Regulatory Issues (Panel), Southeastern Association of Law Schools, Palm Beach, Florida (August 2010) The Shrinking Distinction between Physical Injury, Mental Anguish, Emotional Distress, and Pain and Suffering, (Panel), American Bar Association, Section of Taxation, Annual Meeting, Washington, D.C. (May 2010) Planning a Retreat: Preparing for an ABA Site Visit (Panel), Southeastern Association of Law Schools, Palm Beach, Florida (July 2009) Housing Markets: Incentives, Bailouts, and Social Policy (Panel), American Bar Association, Section of Taxation, Mid-Year Meeting, New Orleans, Louisiana (January 2009) Young Lawyers Roundtable: Effective Preparation & Use of Fact Witnesses at Trial (Panel), American Bar Association, Section of Taxation, Mid-Year Meeting, New Orleans, Louisiana (January 2009) Dealing with Difficult Economic Times (Panel), Southeastern Association of Law Schools, Palm Beach, Florida (July 2008) Young Lawyers Roundtable: Summary Judgment Advocacy (Panel), American Bar Association, Section of Taxation, Annual Meeting, Washington, D.C. (May 2008) Redefining Hobby Losses: Creating Efficiency in Tax Administration (Panel), American Bar Association, Section of Taxation, Mid-Year Meeting, Lake Las Vegas, Nevada (January 2008) Choice of Forum in Tax Litigation (Panel), American Bar Association, Section of Taxation, Mid-Year Meeting, Lake Las Vegas, Nevada (January 2008) Use and Abuse of the Charitable Deduction (Panel), American Bar Association, Section of Taxation, Fall Meeting, Vancouver, BC (September 2007) United States Supreme Court and Legislative Review: Economic Rights and Regulation (Panel), Southeastern Association of Law Schools, Amelia Island, Florida (July 2007) Young Lawyers Roundtable: Access to Information - IDRs and Summons (Panel), American Bar Association, Section of Taxation, Annual Meeting, Washington, D.C. (May 2007) Fifth Amendment Claims in Civil Litigation (Panel), American Bar Association, Section of Taxation, Mid-Year Meeting, Hollywood, Florida (January 2007) The Effect of Murphy on Section 104 Deductions (Ethical Considerations) (Panel), American Bar Association, Section of Taxation, Mid-Year Meeting, Hollywood, Florida (January 2007) United States Supreme Court and Legislative Preview: Economic Rights and Regulation (Panel), Southeastern Association of Law Schools, Palm Beach, Florida (July 2006) New Scholars Workshop (Panel Moderator), Southeastern Association of Law Schools, Palm Beach, Florida (July 2006)

4 PAGE 4 It's Not Easy Being Green: Consumer Tax Incentives from the 2005 Energy Policy Act (Panel), American Bar Association, Section of Taxation, Annual Meeting, Washington, D.C. (May 2006) The Mailbox Rule: The Disconnect of Policy Perspectives and Implementation, American Bar Association, Section of Taxation, Mid-Year Meeting, San Diego, California (February 2006) Weathering Disaster: Tax Implications of Hurricane Katrina (Panel), American Bar Association, Section of Taxation, Mid-Year Meeting, San Diego, California (February 2006) New Scholars Workshop (Panel Moderator), Southeastern Association of Law Schools, Hilton Head, South Carolina (July 2005) Tax Simplification and the Impact on Enforcement (Panel), American Bar Association, Section of Taxation, Annual Meeting, Washington, D.C. (May 2005) United States Taxation: A Global Perspective, Argentinean Delegation of Visiting Attorneys, Baton Rouge, Louisiana (April 2005) United States Taxation: A Global Perspective, Peruvian Delegation of Visiting Attorneys, Baton Rouge, Louisiana (April 2005) How Much Deference is Due: The Internal Revenue Service and Administrative Determinations (Panel), American Bar Association, Section of Taxation, Mid-Year Meeting, San Diego, California (January 2005) Sarbanes-Oxley: Two Years Later (Panel), Southeastern Association of Law Schools, Kiawah Island, South Carolina (July 2004) United States Taxation and the Implementation of Social Policy, Università Commerciale Luigi Bocconi, Milan, Italy (June 2004) Should the Internal Revenue Service be Required to Treat Similarly-Situated Taxpayers Similarly? (Panel), American Bar Association, Section of Taxation, Mid-Year Meeting, Kissimmee, Florida (January 2004) International Discovery in Tax Cases (Inbound Transactions): Letters Rogatory to Foreign Depositions Part II (Panel), American Bar Association, Section of Taxation, Mid-Year Meeting, Kissimmee, Florida (January 2004) International Discovery in Tax Cases (Outbound Transactions): Letters Rogatory to Foreign Depositions Part I (Panel), American Bar Association, Section of Taxation, Fall Meeting, Chicago, Illinois (September 2003) Politics, Elections, and Campaign Finance: Is Reform Necessary? (Panel), Southeastern Association of Law Schools, Amelia Island, Florida (July 2003) The Future of the Law Library (Panel Moderator), Southeastern Association of Law Schools, Amelia Island, Florida (July 2003) Disclosure Of Tax Returns In Non-Tax Litigation (Panel), American Bar Association, Section of Taxation, Mid-Year Meeting, San Antonio, Texas (January 2003) Sarbanes-Oxley Act of 2002: Corporate Reform Through Accounting Scandal, Society of Louisiana Certified Public Accountants, Baton Rouge, Louisiana (January 2003)

5 PAGE 5 PROFESSIONAL SERVICE Southeastern Association of Law Schools o President ( ) o Board of Trustees ( Present) o Deputy Corporate Compliance Officer/Secretary ( Present) Law School Admission Council o Board of Trustees (2010 Present) o Investment Policy Oversight Group (2009 Present, Chair 2011) o Audit Committee ( ) o Finance and Legal (Trustee Liaison 2010) American Bar Association, Section of Legal Education o Site Inspection Team (2009) American Bar Association, Section of Taxation o Vice Chair, Individual Income Tax Committee ( Present) o Chair, Individual Income Tax Committee, Subcommittee on Deductions ( ) o Chair, Court Procedure and Practice Committee, Tax Lawyer Mentor Program ( ) o Special Features Editor, NewsQuarterly ( Present) o Editor, Important Developments in State and Local Taxes, ABA Section of Taxation (2007) o Editor, Important Developments in Energy and Envtl.Taxes, 58 TAX LAW (2005) o Editor, Important Developments in Civil and Criminal Penalties, 57 TAX LAW (2004) CLE and Educational Programs o LL.M. Programs (Panel), Louisiana State University, Baton Rouge, Louisiana ( Present) o Government, Public Interest and Beyond (Panelist), Louisiana State University, Baton Rouge, Louisiana (2004) o Speaker, LSU Continuing Legal Education: Recent Developments Seminar Series (Tax) ( ) o Speaker, LSU Continuing Legal Education: Tax Implications and the Legal Aftermath of Hurricanes Katrina and Rita (2005) o Tax Implications of the Legal Aftermath of Hurricanes Katrina and Rita, Society of Louisiana Certified Public Accountants, Baton Rouge, Louisiana (January 2006) ACADEMIC DEGREES GEORGETOWN UNIVERSITY LAW CENTER, Washington, D.C. Master of Laws (Tax) (with distinction): December 1997 LOYOLA UNIVERSITY SCHOOL OF LAW, New Orleans, Louisiana Juris Doctor: May 1992 Loyola Law Review: Editorial Board (Articles/Casenote Editor) Loyola Street Law Program: Volunteer instructor on legal topics in inner-city high schools UNIVERSITY OF SCRANTON, Scranton, Pennsylvania Bachelor of Science, Accounting (Minor: History), May 1989

6 PAGE 6 LEGAL EXPERIENCE UNITED STATES DEPARTMENT OF JUSTICE - TAX DIVISION, Washington, D.C. (8/97-7/01) Trial Attorney - Civil Trial Section, Southern Region Represented the United States and its officers in litigation of civil tax cases Represented the United States in bankruptcy cases involving federal tax claims Responsible for all phases of litigation from initial pleadings through discovery and trial Outstanding Attorney Award 2000 Representative Cases: National Federation of Republican Assemblies, et al. v. United States of America, et al., 218 F. Supp.2d 1300 (S.D. Ala. 2002), aff d sub. nom, Mobile Republican Assembly v. United States, 2003 WL (11 th Cir. 2003) (political organizations challenge notice and disclosure requirements of 527 under First, Fifth, and Tenth Amendments to maintain tax-exempt status) Retirement Care Associates, Inc., et al. v. United States of America, et al., No. 1:96-CV CAM, 1997 WL and 3 F. Supp. 2d 1434 (N.D. Ga.) (claim for damages in excess of $75M for unauthorized collection/disclosure and refund claim of $4.8M) United States v. Fransen, 98-2 USTC & 50,776, 1998 WL (Aug. 6, 1998), aff=d, 191 F.3d 599 (5th Cir. 1999) (upholding validity of passive activity loss regulations) Chris-Marine, USA, Inc. v. United States, 1998 U.S. Dist. Lexis (M.D. Fla. July 22, 1998); 1998 U.S. Dist. Lexis (Sept. 23, 1998); 1999 U.S. Dist. Lexis 4722 (Mar. 19, 1999) (enforcement of international summons and recovery of attorneys= fees) UNITED STATES DEPARTMENT OF EDUCATION, Washington, D.C. (6/92-8/97) Attorney/Advisor BAR MEMBERSHIPS Drafted opinions for Chief Administrative Law Judge Chair of Committee on Congressional Budgetary Reduction Responsible for development of Informal Dispute Resolution Center, Customer Service Center, and Legal Docketing System Assistant Secretary=s Award for Team Distinction Deputy Secretary=s Award for Service United States Supreme Court United States District Court for the Middle District of Pennsylvania Pennsylvania Supreme Court Maryland Court of Appeals District of Columbia Court of Appeals COMMUNITY AFFILIATIONS NCAA Basketball Official (retired) High School Basketball Official Special Olympics St. Aloysius Catholic Church