Two UNM Law School students won best overall and best written submission in the J.D. division of the 15th Annual ABA Law Student Tax Challenge held in Los Angeles.

The students received first place in the oral arguments for their performance in defending their work product at the competition. They also won for the best written submission, which was decided before attending the meeting.

Frank Cardoza, a third-year law student, said the best written submission award was based on a 10-page partner memo submitted by him and his partner, Scott Woody, and their five page client letter.

The Law Student Tax Challenge was created by the American Bar Association’s Section of Taxation for students to apply classroom knowledge in a real-world setting, Cardoza said. The competition consisted of 65 teams from different law schools throughout the country.

“The competition’s panel of judges consisted of the country’s top practitioners and government officials, including tax court judges. On average, more than 60 teams from law schools across the country compete,” he said.

Woody, a second-year law student at UNM, said the competition consisted of two distinct phases.

The first phase was the written product round, consisting of a 10-page memo to a senior partner and a 5-page letter to the client in response to a hypothetical situation, Woody said. The second phase was an oral defense of the written product.

“The second phase consisted of two rounds,” he said. “The final round was the most difficult as the hypothetical client continually changed the facts in the scenario. The changing fact pattern tested our knowledge of the substantive law and forced us to think on our feet.”

Woody said he and his partner spent about a month developing the issues and researching the underlying law.

“We then spent another month writing and re-writing the papers. Once selected for the oral rounds we practiced presenting to Professors Pareja, Desiderio and Weinstein. We were also afforded the opportunity to present to Tracy Sprouls and Robert Lucero, both of whom practice with the Rodey Law Firm,” he said.

Cardoza said the preparation for the written product started with spotting as many issues as they could, and then researching them.

“At the end of the process, we probably had about 15 working drafts. The writing portion was the most difficult part of the competition,” he said.

In preparation for the oral presentation, they practiced presenting with different mock judges.

Cardoza said the Tax Challenge was one of the best experiences that he has ever had in law school.

“The tax community, as a whole, was extremely welcoming and encouraging,” he said. “The amount of networking that occurred before and after the competition has broadened my horizons and has presented opportunities which I did not think were otherwise possible.”

Cardoza said he would recommend the competition to any students interested in tax law, adding that while it is challenging, the payoff is huge.

The competition was not part of a course, so the victory validated the long nights Cardoza and he put into the completion, Woody said.

Cardoza said he was in disbelief when the awards were announced.

“The name announced did not register with me at first,” he said. “It was just a long string of words. I did not realize what happened until I looked over at Professor Pareja (our sponsor) and she said, ‘We won?’”

He said that was the biggest surprise of the night.

They were sure they had done great work to be invited to the finals, Cardoza said, but to be crowned the best written submission out of the entire country was incredible.

Mary Leto Pareja, an assistant professor of law who was the faculty advisor for the two students, said it took a lot of hard work and dedication over the course of several months to complete the written work product, which the students did on top of a full load of classes as well as family and work obligations.

“While I guided them through the process, all the research and work was theirs,” she said. ” I am happy that their hard work paid off, and I am very proud of them.”

She said she hoped that their success will inspire other students to compete in future years.

“I would love to coach a few teams each year,” Pareja said. “This ABA competition ... adds a real world component to the students’ tax studies, and it helps them hone their research and tax planning skills. It’s also very nice to add some bling to the law school’s trophy case.”

Sayyed Shah is the assistant news editor at the Daily Lobo. He can be contacted at or on Twitter@mianfawadshah.