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SJD Candidate's Essay Wins American Judges Association Award

By Jenny Whalen
Oct. 11, 2013

From winning second prize in the American Judges Association's 2013 Law Student Essay Contest to presenting at the prestigious Commodity Tax Symposium in Canada, fall has been a season of distinction for Michigan Law SJD candidate Amir Pichhadze, LLM '13.

Fresh off his symposium appearance, where he shared a paper on input tax credits with some of Canada's leading commodity tax experts, Pichhadze learned another work of his had won widespread recognition, this time from the AJA.

Writing in the contexts of Canadian law, Pichhadze's article, "Can, and Should, the Parole Evidence Rule Be Invoked by or Against Tax Authorities in Tax Litigation? Distilling Lessons from U.S. Jurisprudence," explores the question of whether and why the parole evidence rule should, or should not, apply to tax authorities.Amir Pichhadze

"In recent years, Canada’s courts have expressed a number of conflicting views about whether the parole evidence rule can be invoked by or against the tax authority in tax disputes," Pichhadze said. "Unfortunately, the courts in these cases did not elaborate, to a sufficient extent, on the justifications for their position on this issue."

However, as Pichhadze notes in his paper, both federal and state courts in the United States have explored the same issue and produced meaningful jurisprudence that he believes can be a source of influence for Canada as well as for any other jurisdiction whose law on this issue may be similarly unsettled and/or underdeveloped.

"The paper invites courts around the world to engage in judicial globalization when considering whether the parole evidence rule ought to be capable of being invoked by or against tax authorities," Pichhadze said. "Considering this targeted audience, it is particularly meaningful to receive this award from the American Judges Association. It is hoped that in the future, courts around the world will follow suit by considering legal transplantation on this issue."

Pichhadze credits the depth of his analysis on this topic to discussions with Daniel Crane, the Associate Dean for Faculty and Research and Frederick Paul Furth, Sr. Professor of Law, while pursuing his international tax LLM.

"My discussions with Prof. Crane were engaging, deep, and inspiring," he said. "All of this contributed to the production of a novel and insightful analysis."

In addition to the recognition from AJA, the article has also been published in the Bulletin for International Taxation (Volume 67, Number 9, Sept. 2013).

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