The US Tax Court (Tax Court) recently announced that Senior Judge Robert P. Ruwe has fully retired as of November 25, 2020, after more than 33 years on the bench. Judge Ruwe graduated from Xavier University and was first in his class in law school at the Salmon P. Chase College of Law. He then joined the Internal Revenue Service (IRS), where he held various positions, including Director, Tax Litigation Division. Judge Ruwe was appointed to the Tax Court in 1987 and, after his 15-year term expired, he served as a senior judge. In 2012, Judge Ruwe received the J. Edgar Murdock Award for his distinguished service to the Tax Court.
At the time of his retirement, Judge Ruwe had authored hundreds of opinions, including many noteworthy concurrences and dissents. Some memorable ones include: (i) Rauenhorst v. Commissioner, 119 TC 157 (2002) (holding that the IRS was bound by its position in published guidance, and treating that position as a concession); (ii) Rhone-Poulenc Surfactants and Specialties, L.P. v. Commissioner, 114 TC 533 (2000) and GAF Corp. v. Commissioner, 114 TC 519 (2000) (addressing complex Tax Equity and Fiscal Responsibility Act (TEFRA) statute of limitations issues); Turner Broad. Sys. Inc. v. Commissioner, 111 TC 315 (1998) (requiring IRS to account for all the results of a transaction when seeking to recharacterize it); and (iv) Wayne Bolt & Nut Co. v. Commissioner, 93 TC 500 (1989) (accounting method changes).
We both served as attorney-advisors for Judge Ruwe in the early 2000s, and benefited significantly from his experience and wisdom. He was an excellent teacher and mentor to us during our time at the Tax Court, taking the time to explain the law and ways in which we could improve our research and writing skills. His grasp and memory of the tax law were extraordinary—he would frequently mention a legal principle and then cite us to the exact TC volume containing the case stating that principle. Additionally, he was interested in our personal lives, and we frequently took long walks with him throughout downtown Washington, DC, discussing not only pending cases but also topics like US history, sports and our families. We wish Judge Ruwe all the best in his retirement!
