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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’s tax controversy experience spans a diverse array of subject-matter areas, including international transfer pricing, foreign tax credits, section 956, and employment taxes. Saul 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 a 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 and 4818-19 (transfer pricing and section 956) (pending)
  • Amazon.com, Inc. & Subsidiaries v. Commissioner, 148 T.C. 108 (2017) (transfer pricing (cost-sharing) issues) (>5-week trial), aff’d 934 F.3d 976 (9th Cir. 2019)
  • The Coca-Cola Company & Subsidiaries v. Commissioner, Tax Court Docket No. 31183-15 (transfer pricing and foreign tax credits; 10-week trial) (pending)
  • Reflectxion Resources, Inc. v. Commissioner, T.C. Docket No. 12017-16 (section 3401(d) and section 530 of the Revenue Act of 1978) (pending)
  • Thomas & Betts Corporation & Subsidiaries v. Commissioner, T.C. Docket No. 4120-17 (transfer pricing) (settled in 2019)
  • Cooper v. Commissioner, T.C. Docket No. 18249-15 (income and deductions, employment status, and additions to tax) (settled in 2019)
  • kgb and Subsidiaries v. Commissioner, Tax Court Docket No. 4667-13 (transfer pricing) (settled in 2017)
  • Appleton v. Commissioner, 140 T.C. 273 (2013) (statute of limitations) (as amicus) (Tax Court adopted position advocated in amicus filing)
  • Baldwin v. United States, Docket 3:12-cv-59 (D. Nev.) (section 165 loss) (settled in 2013)
  • Stander v. Commissioner, Tax Court Docket No. 27114-11 (6015 relief) (settled in 2012)
  • Wrk2trvl, Inc. v. Commissioner, Tax Court Docket Nos. 19229-10 and 19930-10 (S corporation/ESOP; statute of limitations) (settled in 2011)

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 Partner, Tax: US taxes: contentious, The Legal 500 US (2018–2021)

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

Publications

News

Events