Chicago’s John Marshall Law School Takes First Place at Tax Competition for Second Year

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Third-year law students Patrick Bushell and Ryanne Dent took top honors at the Albert R. Mugel Tax Competition in Buffalo, N.Y., both also taking home honors in oral advocacy.

For the second year in a row, students at The John Marshall Law School in Chicago won first place at the Albert R. Mugel National Tax Competition.

Third-year law students Patrick Bushell and Ryanne Dent took the top honors competing against teams representing law schools from across the United States. They also were selected by judges for oral advocate honors in the March 2 competition at the University of Buffalo Law School. Dent was named Best Oral Advocate and Bushell took fourth place Oral Advocate. They were coached by Professor Arthur Acevedo.

Students in the competition argued the fictitious case Commissioner of the Internal Revenue v. Mugel Motors Inc.

The facts of the case were: the company laid off 8,000 employees and paid the released employees severance payments. The company withheld FICA taxes on the amounts paid. The Company then filed a suit seeking a refund of the FICA taxes paid arguing the amounts paid were exempt from FICA taxes because they were Supplemental Unemployment Benefits and therefore were not wages subject to FICA tax.

The company argued that Rowan Cos., Inc. v. United States was not overruled and therefore the definition of wages, which is the same for withholding tax and FICA tax purposes, should not be expanded to include Supplemental Unemployment Benefits.

Moot Court is the simulation of appellate argument. At The John Marshall Law School it is one of the excellent opportunities law students have to develop written and oral advocacy skills. John Marshall students compete and have gained national recognition in an estimated 30 competitions each year. For additional information, visit

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Marilyn Thomas
The John Marshall Law School
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