Chuck Hodges and Melissa Mitchum among Law360's MVPs for 2024
Jones Day's Chuck Hodges and Melissa Mitchum have been named 2024 MVPs by Law360. The MVP list is the legal news service's annual selection of leading lawyers in a range of practice and industry categories. Mr. Hodges, a partner in the Firms Tax Practice, was recognized as a Tax MVP. Ms. Mitchum, of counsel in Firm's Financial Markets Practice, was recognized as a Complex Financial Instruments MVP. Law360's MVP awards honor elite attorneys for their successes in high-stakes litigation, significant deals, or complex global matters in the previous year.
Mr. Hodges focuses his practice on federal tax controversies and litigation and assists U.S. taxpayers facing tax disputes around the world. He has filed at least 150 petitions in U.S. Tax Court over his 27-year career, that span tax disputes involving large international corporations to pro bono matters for innocent spouses. He recently won a complete victory for taxpayer/client, Parkway Gravel, before the U.S. Tax Court as sole trial counsel in an economic substance case. In that trial, Mr. Hodges proved that a transaction involving the sale of parcel of property between a taxpayer and its related "development arm" of a larger group of road construction and real estate companies was an ordinary business transaction with a business purpose and economic substance. The Court held that the option agreement was not a "factual sham" and the taxpayer was entitled to like-kind exchange treatment. Mr. Hodges also won an $86 million dollar concession from the IRS after a week-long trial in U.S. Tax Court involving the valuation of two motion pictures for charitable contribution purposes and bad debt expenses relating to multimillion-dollar loans made by Jackson Investment Group in the secondary lending market. Facing a $90 million assessment, he dismantled the IRS case, disqualified the IRS' valuation expert, and earned a nearly complete victory for the taxpayer.
Ms. Mitchum practices primarily in the areas of structured finance, project finance, and securitization. As part of the Firm's representation of a major energy company's various roles in a $18.5 billion project financing for a liquid natural gas export facility in the United States, she led the financing team negotiating the company's equity investment in the export facility's joint venture, as well as the debt facility for which the Company acted as a credit support provider. It is the first U.S. LNG project offering CO2 emissions reduction of more than 90 percent via planned carbon capture, and the phase one project financing was also the largest greenfield energy project financing in U.S. history. Ms. Mitchum also led the structured finance team representing Guidehouse, Inc., in connection with a first-of-its-kind multi-seller securitization of the unguaranteed portion of Small Business Administration 7(a) loans. The multi-seller structure provides community and regional lenders the opportunity to participate in a market previously closed to them and tap into sources of liquidity that were previously unavailable. She also led the financing team for Waga Energy in its first U.S. project financing to complete construction and installation of its Wagabox® technology in multiple landfills in the United States, which involved revising aspects of the structure to account for a French parent company guarantee and the issuance of notes to French investors.
