After majoring in accounting at the Wharton School, I actually entered law school (in 1963) with thoughts of being a tax lawyer. Bernie Wolfman’s course in basic income tax (he was visiting at Harvard in 1964) made me even more enthusiastic. Immediately after law school, I joined the Philadelphia law firm of Wolf, Block, Schorr & Solis-Cohen, the firm where Bernie Wolfman had been a partner. It was a large firm (by 1966 standards) of 60+ lawyers. I didn’t know how to spend my huge $7,800 salary. (Within one year our salaries were raised to $13,500, when New York firms dramatically raised starting salaries to $15,000).
I spent exactly one day “rotating” through the firm’s various departments. On my second day, the senior tax partner asked me if I would like to join the tax department and I accepted. Then, about two years after I entered the firm, Jerry Kurtz returned to the firm from his tour at Treasury as Tax Legislative Counsel under Stanley Surrey. Jerry introduced me to the tax expenditure budget, and I was forever hooked on tax policy. Actually, I think I always enjoyed talking about tax and tax theory more that practicing tax law. (In fact, some of the firm’s partners often had to remind me that I was part of a business firm.)
The movement from the law firm to the academy was more problematic. I loved the thought of being an academic, but I thought I was a bit shy to stand in front of a class. However, during my fifth year at the firm, over a period of several months, I was asked to do presentations to the firm on a variety of issues (stock options, real estate investment trusts, and professional corporations). These presentations were very well received and my reputation in the firm soared. So, before they realized at Wolf, Block that I was all talk, I applied for law teaching jobs and landed one at Maryland. I was extremely pleased, although my father asked my wife whether I was being fair to her and my children, giving up a potentially lucrative career for the classroom, but I digress.
During my first year at Maryland, I was promised an easy schedule by the Dean; that schedule consisted of two sections of income tax, and one of corporate tax, estate and gift tax (which I had never practiced), and a tax policy seminar. I always wondered what a hard schedule would have been like. Anyway, I loved teaching from the first day, and, thirty five years later, my feelings are unchanged. I feel the same enthusiasm and rapport with the students that I did then. I still feel young, even though some of my former students have already retired from practice. I still get a charge every time a student comes into my basic tax class gritting his or her teeth, and leaves with thoughts of becoming a tax lawyer. I am delighted that my former students now serve on the Tax Court, as law professors, in government, and in firms throughout the country.
I still remember my excitement when one of my earliest articles on interest-free loans was used as the basis for a “brilliant” dissent by the late Judge Irving L. Goldberg of the Fifth Circuit in a case called Martin v. Commissioner. Then a few year’s later, Joel Newman wrote a piece entitled “Determining Value in Barter Transactions: A Response to Robert Keller’s The Taxation of Barter Transaction.” I was in heaven: my name was actually in the title of someone else’s article.
For thirty of my thirty five years at Maryland, I have shared the tax teaching with my friend and colleague, Dan Goldberg. To this day, we never seem to run out of tax talk. Dan’s recent writings on the implementation of a consumption tax have helped make me become totally conversant with all of the exotica of that area.
I am currently teaching courses in income tax and business tax, as well as a new offering I call “Tax and Financial Planning for Individuals.” I am also working on an article on the asymmetry of the tax law (i.e., all those areas in which recoveries of previously paid items would be nontaxable, even though nonrecoveries would result in either no deduction or only a limited deduction).
Who could ask for anything more?
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