I doubt I have convinced anyone. Perhaps my arguments have lacked passion.
Today I try passion. You need to know something about me. Growing up my mother endured many parent-teacher conferences where she heard a consistent story. Her son was an academic underachiever.
My mother was a 4.0 student through high school. She openly admitted she just outworked everyone else. My teachers said my test scores were extremely high but, in class, I was disinterested.
The apple fell far from the tree. Yet my mother never told me to shape up. She knew me. I didn’t know me. I had to learn, and it was difficult.
The kids I hung out with in those days did not champion academic achievement. I didn’t either. Except for a few times.
In fifth grade, we had to build something historical. I chose an Inca village. I worked for three weeks using clay from the creek banks that slowly hardened.
In the end, I had my own Machu Picchu. It was so heavy my Dad had to come with me to P.S. 4 to help carry it to our class. As I walked in, I expected to see other masterpieces.
Other kids had used a shoebox to craft some silly thing the night before it was due. I was mortified.
I had a huge wooden board with a clay village of many buildings. Friends couldn’t understand why I spent so much time on it. Neither could I.
In seventh grade math class we were told there was a schoolwide contest to see how many permutations, or arrangements, one could make. I spent all evening on it and got somewhere in the 700s. The next closest kid was in the 300s.
Again, I felt embarrassed I had spent so much time. There were one or two legitimate math geniuses in my school and I trounced them. I knew it was because I had taken the task a bit too seriously.
It took me years to be comfortable with the pursuit of intellectual challenges. When I told my mother I got a 4.0 my first year in college she was unmoved and just said, “that doesn’t surprise me.” I felt like screaming, “Well, it shocks everyone else!”
Comfort in intellectual pursuit led me to tax practice. Transactional tax planning is intellectually difficult. It takes time, effort, study, thought, research, analysis, trial and error. There are false starts and dead ends.
When I was mature enough to want to build an Inca village with my mind, to want to be Mr. Permutation, tax practice fit my needs.
I have taught my kids to willingly be exposed to new ideas. Listen. Then critique. Learn to think and to analyze.
William James said, “A great many people think they are thinking when they are merely rearranging their prejudices.”
Aristotle said, “It is the mark of an educated man to be able to entertain a thought without accepting it.”
In the early days of my tax career, we did detailed research and wrote critical analysis of transactional ideas and possible challenges to those ideas.
It may be hard to believe, but tax practice was building villages of ideas and then testing them to see if they would crack when subjected to the elements.
And there were elements. The IRS was funded and its agents trained. The audit rate was relatively high. My firm taught we had to get things right. There were consequences.
The IRS, too, had a village built of clay and its permutations were many. You had to be on your intellectual game. It was a challenge.
Now the poorly funded IRS drags in a shoebox with a few paper-mâché buildings and people made of cigar cleaners. Why build a clay village to compete with that?
Tax practice has become increasingly intellectually lazy. People want quick answers and the audit rate means no one is likely to challenge those answers.
I hope I never feel embarrassed to spend hours researching, formulating and challenging a tax idea.
Poor IRS funding leaves us with a tax system that rewards intellectual bankruptcy and is undeserving of a great democracy.
James R. Hamill is the director of tax practice at Reynolds, Hix & Co. in Albuquerque. He can be reached at email@example.com.