TaxProf Blog

Wendy Gerzog (Baltimore)

• B.S. 1968, Clark
• M.A. 1971, Assumption
• J.D. 1976, Akron
• LL.M. (Tax) 1979, George Washington

Like many others, particularly women, I took an indirect route to becoming a lawyer.

A night student in my senior year of college, I worked in the actuarial department of an insurance company, but soon found myself being trained in Fortran and Cobol at “IBM School.” I disliked programming and so, when I graduated, I very happily quit and began teaching dramatics at Lincoln House, a girls club. I then got my master’s degree in English, taught high school English, and had fun directing the junior and senior class plays (“R.U.R.” and “The Bald Soprano”). Having by that time moved from Massachusetts to Ohio, I took the rest of my required Ph.D. classes in English and taught freshman literature at Kent State. Because I was evidently still “finding myself,” I considered taking a one-year leave of absence to try law school. I drove over to the University of Akron, talked to the Associate Dean, applied and began law school that fall. I was one of those people who actually loved law school. Because Ohio tested on Income Tax, Corporate Tax, and Estate and Gift Tax, I took several tax courses and was surprised to do well in them.

After graduating, I became a teaching fellow at GW, completing my LL.M. in Taxation. My favorite courses were Partnership Tax (taught by Mike Sanders) and Tax Policy (taught by Tom Field). My paper on the marriage penalty (The Marriage Penalty: The Working Couple’s Dilemma, 47 Fordham L. Rev. 27 (1978)) became my first real law review article (apart from a student piece on Karen Quinlan).

One of my best tax experiences was clerking for Judge Tietjens at the U.S. Tax Court. He was such a wonderful man and mentor; he had also taught high school English, enjoyed crossword puzzles, and had a great sense of humor. During my interview, I couldn’t help but notice that he had pinned a newspaper photo of Gerald Ford onto a tapestry next to a griffin that looked like Ford’s twin—I knew I wanted to clerk for him. Anyway, in my last year clerking on the court, I was pleased to be asked to review the opinions of the Special Trial Judges for the then Chief Judge Tannenwald. It was in that year that I gave birth to my son Alex (appropriately, on Mother’s Day). As for teaching tax law, I was lucky that Jack Lynch, my officemate at GW, remembered me and called me when the University of Baltimore was looking for a tax professor. I have been very happy at UB and have had great colleagues there (Jack Lynch, Walter Schwidetzky, and Fred Brown). I am among those who are extremely grateful and astonished that we are paid for what we do.

For the past ten years, I have written mostly in the areas of estate and gift tax:

• Actuarial Tables v. Facts and Circumstances Valuation: Ithaca Trust Re-visited, 38 Real Prop., Probate, & Trust J. 745 (Winter 2004) [blogged here and here]
• Contingencies and the Estate Tax, 5 Fla. Tax Rev. 49 (2001)

I think I have cornered the market on QTIP articles:

• Solutions to the Sexist QTIP Provisions, 35 ABA Real Prop., Probate, & Trust J. 97 (2000)
• The Illogical and Sexist QTIP Provisions: I Just Can’t Say It Ain’t So, 76 N.C. L. Rev. 1597 (1998)
• Clack Estate: Adding Insult to Injury, or More Problems with the QTIP Tax Provisions, 6 S. Cal. Rev. L. & Women’s Stud. 201 (1996)
• The Marital Deduction QTIP Provisions: Illogical and Degrading to Women, 5 UCLA Women’s Law J. 301 (1995)

I’m currently writing a column (“Estate and Gift Rap”) for Tax Notes. Some recent pieces for the column have included:

• Return to Senda:  Order Determinative for FLP Discounts, 110 Tax Notes 791 (Feb. 6, 2006) [blogged here]
• Donovan and Davis: Two More Lottery Cases, 110 Tax Notes 543 (Jan. 30, 2006) [blogged here]
• Kelley:  A Green Light for FLPs, 109 Tax Notes 1467 (Dec. 12, 2005) [blogged here]
• Duty of Consistency and the Marital Deduction: Horse and Carriage, 108 Tax Notes 1463 (Sept. 19, 2005) [blogged here]
• It’s Summertime With Iced Tehan a TAM, 108 Tax Notes 603 (Aug. 1, 2005) [blogged here]
• Bongard’s Nontax Motive Test: Not Open and Schutt, 107 Tax Notes 1711 (June 27, 2005) [blogged here]
• The Final GRAT Regulations: Schott Shot Down, 107 Tax Notes 1175 (May 30, 2005) [blogged here]
• How Do D’Ambrosio and Wheeler Fit into the FLP Debate?, 107 Tax Notes 387 (Apr. 18, 2005) [blogged here]
• Davis and Whiting: QTIP Income Interests and Intent, 106 Tax Notes 1597 (Mar. 28, 2005) [blogged here]

Now that my two children (I also have a daughter, Amelia) are grown, I am enjoying my visits at Seattle University and at New England School of Law. I am married to Harry Cohen– an avid chess player, a semi-retired transportation planner, and a great guy.

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