Morgan Lewis

Saul Mezei

Partner

Saul Mezei represents clients at all stages of federal tax controversy, from audit and administrative appeals to trial and judicial appeals. Saul focuses on all aspects of international transfer pricing, with an emphasis on issues relating to intangibles. He also advises on a variety of other complex domestic and international issues.

Extended Profile

Saul is an adjunct professor in the Graduate Tax Program at the Georgetown University Law Center, where he currently teaches "Survey of Transfer Pricing" and previously taught "The Life of a Tax Controversy." He is the co-author of "Transfer Pricing: Litigation Strategy and Tactics," BNA Tax Management Portfolio, 893 T.M. (forthcoming). He is an active member of the J. Edgar Murdock American Inn of Court and of the American Bar Association Section of Taxation and Federal Bar Association Section of Taxation.

Saul previously served as attorney-advisor to Judge Robert A. Wherry Jr. of the United States Tax Court. He was also senior law clerk to Judge Lawrence B. Hagel of the United States Court of Appeals for Veterans Claims.

Prior to joining Morgan Lewis, Saul was a partner in the corporate practice of another international law firm.

selected representations

Representative docketed cases in which Saul has appeared as a counsel of record, or participated significantly, include:

  • Western Digital Corporation & Subsidiaries v. Commissioner, T.C. Docket No. 18984-18 (transfer pricing and section 956)
  • The Coca-Cola Company & Subsidiaries v. Commissioner, Tax Court Docket No. 31183-15 (transfer pricing) (pending)
  • Thomas & Betts Corporation & Subsidiaries v. Commissioner, T.C. Docket No. 4120-17 (transfer pricing) (pending)
  • Cooper v. Commissioner, T.C. Docket No. 18249-15 (income and deductions, employment status, and additions to tax))
  • kgb and Subsidiaries v. Commissioner, Tax Court Docket No. 4667-13 (transfer pricing) (pending)
  • Amazon.com, Inc. & Subsidiaries v. Commissioner, Tax Court Docket No. 31197-12 (transfer pricing) (pending)
  • Baldwin v. United States, Docket 3:12-cv-59 (D. Nev.) (section 165 loss)
  • Martin 1999 Irrevocable Trust v. United States, Ninth Circuit Docket No. 11-17879 (TEFRA; limitations period)
  • Stander v. Commissioner, Tax Court Docket No. 27114-11 (6015 relief)
  • Wrk2trvl, Inc. v. Commissioner, Tax Court Docket Nos. 19229-10 and 19930-10 (S corporation/ESOP; statute of limitations)
  • Appleton v. Commissioner, Tax Court Docket No. 7717-10 (statute of limitations) (as amicus)

Education

  • Georgetown University Law Center, 2009, Master of Laws, With Distinction, Dean’s List
  • Benjamin N Cardozo School of Law, 2002, Juris Doctor, cum laude, Order of the Coif
  • University of Baltimore, 1999, Bachelor of Arts, magna cum laude

Admissions

  • District of Columbia
  • Maryland
  • New York
  • US Court of Appeals for the Ninth Circuit
  • Supreme Court of the United States
  • US Tax Court

Clerkships

  • Attorney-advisor to Judge Robert A. Wherry Jr. of the US Tax Court
  • Clerkships to Judge Lawrence B. Hagel of the US Court of Appeals for Veterans Claims and Chief Judge Kenneth B. Kramer (2002 - 2003)

Awards and Affiliations

Next Generation Lawyer, Tax: US taxes: contentious, The Legal 500 US (2018–2020)

Rising Star, Tax, Law360 (2018)

Member, Practice Group of the Year, Tax, Law360 (2017)

Member, J. Edgar Murdock American Inn of Court

Member, American Bar Association Section of Taxation

Member, Federal Bar Association Section of Taxation

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