After graduating regulation college, I made a decision to pursue an LLM in taxation, partially to defer pupil mortgage repayments till after I graduated. I began at Chapman Legislation College earlier than transferring to Loyola Legislation College in Los Angeles as a result of the college was nearer to my house. It was there I met somebody who would have a profound and constructive impression on my research and past.
One of many courses I selected was referred to as Tax Features of Enterprise Planning. It was taught by Professor Dean Weiner who earlier than becoming a member of academia was a companion at O’Melveny & Myers the place he practiced tax regulation for a few years. Each few weeks, a brand new, complicated truth sample was offered (presumably coming from his work at O’Melveny), and we’d submit an in depth tax evaluation with a proposed resolution. I took a liking to this class as a result of it match my studying fashion higher. I made it a degree to take any future courses with him.
I ought to be aware that I had a classmate who was actually good though I didn’t speak to him a lot outdoors of sophistication. I later discovered that he was Above The Legislation and Wall Road Journal’s Lawyer of the 12 months. However I digress.
That September, the ABA Part of Taxation launched the issue for his or her annual Legislation Pupil Tax Problem (LSTC). The actual fact sample concerned a purchase order of a non-public firm by means of a tax-free reorganization construction in addition to an govt compensation challenge. I made a decision to enter it and, in mild of Weiner’s experience in enterprise taxation, requested him to be our group’s coach.
Briefly, we handled the competitors as if this was one other one in every of his assignments. I might write a proposed resolution, and he would critique it. However we had one main drawback which was the manager compensation portion of the issue. First, govt compensation didn’t appear to be Weiner’s forte. Second, the issue concerned the newly enacted Part 409A which created very complicated tax guidelines concerning deferred compensation in response to the Enron chapter in 2001. For this portion, I feared that I used to be just about alone.
Since Weiner was my professor and coach, we obtained to know one another fairly effectively over the semester. Along with courses and the competitors, we’d speak extensively about tax coverage, and he would share his conflict tales about mergers and tax controversies.
That December, the LSTC’s co-chairs knowledgeable us that we have been the finalists within the competitors. That meant that we’d fly out to Miami to take part within the last oral competitors on the Part of Taxation’s midyear assembly. Weiner was simply as excited as we have been, and he took nice lengths to assist us put together. He even invited us to his workplace at O’Melveny the place he and others from their tax division supplied steerage.
I recall being nervous that day because the judges have been well-known tax attorneys and a United States Tax Courtroom Choose. I’m positive my nervousness was proven through the oral competitors.
I didn’t win, though one other group from Loyola received first place. However regardless, it was an excellent expertise and I’m grateful to the Tax Part for the expertise and offering the lodging. All of us went out to dinner afterward the place all of us had enjoyable and, for just a few hours, we talked about something aside from tax.
The following day, all of us went to the airport to return house. I bear in mind telling Weiner I used to be contemplating writing a analysis paper on the taxation of online game currencies, a subject that drew some debate on the time. However he mentioned he had a headache and deliberate to take a nap when he obtained again house. All of us had a memorable night so being a bit underneath the climate was excusable.
A number of days later, the reminiscences have been behind us and it was again to enterprise as traditional. However at school, I observed that Weiner’s speech was slower than regular, and he appeared to have bother remembering issues. After I met with him throughout his workplace hours to assist with a aspect undertaking he was doing, he appeared absentminded at instances. I believed it was merely jet lag that may go away in just a few days.
Every week later, all of his courses have been canceled indefinitely. Clearly, one thing was critically mistaken.
Quickly after, the college instructed us that Weiner underwent surgical procedure to take away a mind tumor and, in consequence, another person would educate the category for the remainder of the semester. A while later, we obtained an replace saying that he was resting at house. Whereas I used to be involved about his situation, I made a decision it might be finest to simply ship him an e-mail and hope that he would reply when he recovered.
I might not get an replace on his situation for a yr. In the midst of February 2008, the college despatched me an e-mail stating that Dean Weiner handed away on Valentine’s Day.
It’s been 14 years since his passing. For me, he made finding out tax regulation enjoyable, and I imagine his affect had an impact on my future efficiency at college. That analysis paper I discussed become my honors analysis paper. It was printed at a high tax regulation journal and was devoted to his reminiscence.
I’m pleased that I used to be in a position to present Prof. Weiner with a second of satisfaction within the sundown of his life. However at instances, I want he was nonetheless round as I’m sure that he and I might have stayed in contact. The me in 2007 would have hoped he might join me with individuals who might assist me discover a job after commencement. However right this moment, I might need to attain out to him to get recommendation on tax points and regulation observe. However I do know he would ask for my ideas and critique them simply as he did once I was a pupil.
Steven Chung is a tax lawyer in Los Angeles, California. He helps folks with primary tax planning and resolve tax disputes. He’s additionally sympathetic to folks with giant pupil loans. He will be reached by way of e-mail at email@example.com. Or you possibly can join with him on Twitter (@stevenchung) and join with him on LinkedIn.