The Supreme Court has ruled 7 to 2 in favor of the government in Moore v. United States, and we have assembled a panel of experts, including counsel for plaintiffs Charles and Kathleen Moore, the government’s chief litigator in the lower courts, and the author of an amicus brief to discuss their decision. What are the implications of the Court’s decision? What factors helped shape it? How will the decision affect the tax landscape?   

Tax Analysts is offering this episode of Taxing Issues as a free service to the public, and all attendees can receive CPE credits. To do so, you must register for the webcast before it starts and log in no later than the scheduled start time. You also must request CPE credits before each webcast, and you must answer the polling questions that will be asked throughout the event. 

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Cara Griffith
President and CEO, Tax Analysts

As the moderator for our Taxing Issues webinars, Cara objectively analyzes issues and asks probing questions that challenge panelists to explain and defend their positions.

When she’s not moderating Taxing Issues webinars, Cara provides strategic oversight for Tax Analysts. She has led efforts to improve the Tax Notes suite of products and to aggressively pursue transparency in the administration of tax systems. Previously, Cara managed the editorial department, including the flagship daily news publications and weekly magazines. She has written for a broad range of tax policy publications, including Tax Notes State, The Tax Adviser, The Hedge Fund Law Report, and The Hill. She regularly speaks at tax conferences and other events, discussing a variety of technical tax issues as well as the need for transparency in tax administration.

Cara has a BA in political science and a BA in international studies from the University of Evansville and a JD from the George Washington University Law School.

Andrew Grossman
Partner and appellate and major motions team co-leader, Baker & Hostetler LLP

Andrew M. Grossman is a partner at BakerHostetler and leads the firm’s appellate and major motions practice. He is also an adjunct scholar at the Cato Institute, a senior legal fellow at the Buckeye Institute, and a member of the leadership of the Federalist Society. He is counsel of record for the petitioners in Moore v. United States, which he argued before the Supreme Court in December 2023.  

Jeffrey Paravano
Partner and tax group chair, Baker & Hostetler LLP

Jeff Paravano is the firmwide chair of BakerHostetler’s tax group and managing partner of the firm’s Washington office.  He has been the lead litigator or the key tax team member in more than 30 tax cases and is the tax counsel of record in the Moore v. United States Supreme Court tax case. He previously served as Treasury senior adviser to the assistant secretary, tax policy.  

While at Treasury, Paravano provided advice on a wide range of tax policy and technical issues, including tax legislation and corporate, partnership, REIT, and financial sector tax guidance.  He also was one of the primary authors of the final tax shelter regulations; wrote Tax Management Portfolio, Tax Shelters, T.M. 798; and coauthored Tax Management Portfolio, Reportable Transactions, T.M. 648-2nd. He has a broad-based tax practice that includes buy-side mergers and acquisitions, international restructurings, and tax controversy and litigation.  

Nathaniel Pollock
Partner and tax controversy practice lead, SouthBank Legal

Nate Pollock focuses his practice on federal tax controversy, particularly tax litigation. He founded and leads SouthBank Legal’s tax controversy practice and represents businesses and individuals at all stages of a tax dispute, including IRS examinations, administrative appeals, and trial-level and appellate litigation. Currently, he represents businesses with multimillion-dollar tax disputes in Tax Court and at IRS Appeals. He also helps clients evaluate the litigation risk inherent in tax positions they are contemplating. 

Before joining SouthBank Legal, Pollock was one of two senior-level attorneys in the Department of Justice Tax Division’s appellate section, where he handled the government’s most significant and challenging tax appeals. He won multiple awards from the Justice Department for his work.  

Pollock has litigated tax cases involving a range of issues, including serious constitutional challenges to tax laws, Administrative Procedure Act challenges to Treasury regulations, federal law treatment of the cannabis industry (section 280E of the code and cost of goods sold), international tax issues (interpretation of tax treaties, the mandatory repatriation act, transfer of intellectual property to a related foreign entity, etc.), challenges to denials of tax-exempt status, the alternative fuel mixture credit, and more.  

Pollock assists SouthBank Legal’s other litigators as a seasoned “issues and appeals” attorney. He has filed many dozens of briefs in the federal courts of appeal, as well as at least a dozen in the U.S. Supreme Court, and has represented the government at oral argument more than 25 times.  

Andy Grewal
Orville L. and Ermina D. Dykstra Professor in Income Tax Law, University of Iowa College of Law

Andy Grewal is the Orville L. and Ermina D. Dykstra Professor in Income Tax Law at the University of Iowa College of Law. He joined the Iowa faculty in 2011. In 2022 students of the law college voted him Professor of the Year. 

Professor Grewal’s scholarly interests relate to tax law, administrative law, statutory interpretation, and constitutional law. He has testified before Congress on tax administration issues, and his scholarship in that area has formed the basis for several taxpayer challenges to Treasury's regulatory authority, including in cases before several U.S. circuit courts of appeal. The Supreme Court cited professor Grewal in a case involving a complex tax shelter, and the Tax Court heavily relied on his regulatory interpretation scholarship in an opinion issued by the full court. Professor Grewal’s research on constitutional issues related to presidential power has been cited or discussed in numerous national publications. He writes about current legal controversies at Notice & Comment, the blog of the Yale Journal on Regulation. His Notice & Comment posts have been heavily relied on in petitions for certiorari before the Supreme Court. 

Before joining academia, professor Grewal practiced in the Washington office of Skadden, Arps, Slate, Meagher & Flom, where he worked on a variety of matters related to international tax planning, tax policy, and mergers and acquisitions. He received his JD from the University of Michigan, where he was a contributing editor on the Michigan Law Review and was awarded the Richard Katcher Senior Tax Prize. After law school, he received a full merit scholarship to attend Georgetown University as a graduate tax fellow and was awarded an LLM in taxation with honors.