July 14, 2007
Fred B. Brown (Baltimore)
- B.S. 1982, Rutgers
- J.D. 1985, Georgetown
- LL.M. (Tax) 1986, NYU
I believe that my interest in tax law stemmed from my background as an engineering major in college. Engineering students are often working with complex formulas and applying them to factual situations. I see the work of tax professionals as similar, given that the Code is composed of formulas – expressed in prose instead of symbols, but formulas nonetheless. Engineering students also often use diagrams to analyze situations, another element in common with the study and application of tax law.
While in law school at Georgetown, I took several tax courses, and having enjoyed them, I decided to pursue an LL.M. in Taxation at NYU immediately following law school. My favorite course at NYU was Tax Policy with Noel Cunningham, which really helped to tie everything together and give it meaning. I was fascinated by Noel’s explanation of tax theory, and I think it was at this point I decided that teaching and writing about tax law was the thing for me.
During my second semester at NYU, I became aware that the school was accepting applications for positions as acting assistant professors in the graduate tax program. I jumped at the opportunity, and was very fortunate to receive one of the appointments. It was a wonderful and valuable experience. I learned a great deal about teaching from the very talented teachers on the tax faculty there, in particular, Noel, Deborah Schenk, Brooks Billman, and Lenny Schmolka. I also benefited a lot from my student evaluations, which at first were quite poor and then got progressively better. Even though I didn’t write while at NYU, I still learned something about scholarship. I was quite honored and surprised when Noel and Deborah asked me to read and comment on their pieces, and even more so when they seemed to listen to what I had to say. They have been great mentors, and I owe them a lot for all of their help and advice.
After my two years of teaching at NYU, I had pretty much decided that I wanted a career as a tax professor. Nevertheless, I felt that I had to practice tax law – I might enjoy it, and at very least, the experience of practicing tax law should help to make me a better teacher and scholar. I took a position with Shaw Pittman in Washington, D.C., working in the firm’s tax group. There I worked mainly with several excellent attorneys in addressing the taxation of foreign corporations with U.S. business operations. It was my first exposure to international taxation, and the work was quite exciting and challenging, especially since we were working on many cutting edge issues raised by recently promulgated regulations dealing with the branch profits tax, the excess interest tax, and interest expense deductions.
While I enjoyed and benefited from my time in private practice, after a couple of years I felt it was time to begin my career as a tax professor. I was fortunate to receive an appointment at the University of Baltimore School of Law, and I have been there ever since, primarily teaching tax courses in the school’s graduate tax program (which I have directed since 1999). The graduate tax classes at the University of Baltimore contain a mix of lawyers (going for an LL.M. in Tax), accountants (going for an M.S. in Tax), and law students, and this provides an interesting learning environment for the students as well as for me. Like other law teachers, I am constantly learning from my students, both with respect to teaching technique and the law, and their inquisitive minds force me to continue learning and developing as a teacher and tax professional. I still get a high when a class goes well, and a bit of a low when it doesn’t. Like many teachers, I find it quite gratifying when I see that the students really do get it, and that I had something to do with it.
My scholarship has focused on some fundamental issues, such as realization and nonrecognition, as well as on international tax issues. Like many others, I am somewhat frustrated over the complexity of the tax system and how irrational it is in some respects, and I aim to find a better way. I have benefited greatly from my wonderful tax colleagues at Baltimore -- Walter Schwidetzky, Wendy Gerzog, Jack Lynch and Keith Blair. Through our frequent discussions of tax issues and reviews of each other’s articles, I have learned a great deal about tax and writing about tax. I value their friendship and support.
When I am not busy with school work, I enjoy spending time with my wonderful spouse, Grace, and my three great kids, Molly, Aaron, and Reed. We enjoy playing (or watching in my case) sports, riding bikes, hiking, playing games, and just hanging out talking or watching TV/movies. We also take at least one long family vacation each year, and are about to leave for China and Taiwan. Grace and I realize how fleeting the time is that parents have with their children, and we make an effort to spend as much time with them as possible. I also do quite a bit of running. My very good friend and (nontax) colleague, Don Stone, and I run together frequently, including several marathons. We are currently training to run a half marathon in the fall. What we lack in speed we make up for in style (well not really).
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