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THE TAX LAWYER’S ROLE IN THE WAY THE AMERICAN TAX SYSTEMWORKSBy Mortimer M. Caplin

It is a high privilege to be asked to deliver this ErwinN. Griswold Lecture and a treat too to see so many oldfriends and meet so many new ones. In honor of ournamesake, I would like to touch on four matters ofrelevance: (1) Dean Griswold’s effect on the tax law, (2)the role of the U.S. Tax Court, (3) the role of the IRS, and(4) the tax lawyer’s role in the way the American taxsystem works.

I

My first contact with the Dean was in my early days asa young law professor at the University of VirginiaSchool of Law — struggling in the classroom usingGriswold, Cases and Materials on Federal Taxation. Not thatthe casebook was entirely new to me; for, with the goodhelp of the G.I. bill, I’d become well-acquainted with it atNYU in my post-World War II doctoral efforts. It’s hardto believe, but the Griswold casebook was the first everdevoted entirely to federal income taxation, and it proveda godsend to me as I segued from New York law practiceto teaching at UVA in the fall of 1950.

Erwin Griswold and I met at law professor gatheringsand bar meetings, especially in the early 1950s at Ameri-can Law Institute sessions in Washington as members ofALI’s Tax Advisory Group. We both were hard at workon its comprehensive tax report, which later became partof the 1954 code. Never did I tell him though that, inusing his casebook, my custom was to try a personaltouch by distributing mimeograph materials that totallyrearranged the order of presentation and reading assign-ments. Nor did I ever hint that, after a year or two, Iswitched entirely to his major competitor, the morecomprehensive Surrey and Warren. He probably learned

about it faster than I thought skimming through hisroyalty reports — reports that he undoubtedly scruti-nized with great care.

He had graduated from Harvard Law School in 1929,and his first real contact with the tax law was during hisfive-year stint as a fledgling attorney in the Office of theSolicitor General of the United States. Federal tax ratesand tax receipts were at a low point then and handlingtax cases was not the most sought-after assignment. Bydefault, he soon became the office’s tax expert, arguingthe bulk of its tax cases both in the U.S. Supreme Courtand the U.S. Courts of Appeals. I should mention that,just before leaving the S.G.’s office, he was instrumentalin the rule change that allowed appeals in tax cases to bemade under the general title ‘‘Commissioner of InternalRevenue,’’ without the need to specify the name of theincumbent. That’s why you see older tax cases bearingthe names of particular commissioners — David Burnetor Guy T. Helvering, for example — and, later, hardly anywith names like Latham, Caplin, Cohen, Thrower, andthe like. Let me mournfully add: ‘‘Sic transit gloria mundi’’— so passes away the glory of this world!

Erwin Griswold left the S.G.’s office in 1934 to becomea Harvard Law School professor for 12 years, and thendean for the next 21. He had a major influence on tens ofthousands of law students as well as lawyers throughoutthe world. As years went by, he reminisced that he found‘‘less exhilaration’’ in teaching the federal tax course as‘‘the tax law had become far more technical andcomplicated . . . In the early days, the statute was lessthan one hundred pages long and the income taxregulations . . . were in a single, rather slight, volume.’’Oh, for the good old days!

Griswold was instrumental in the rulechange that allowed appeals in taxcases to be made without the need tospecify the name of the incumbentcommissioner. ‘Sic transit gloriamundi!’

In the fall of 1967, he returned to the S.G.’s office, butthis time as the Solicitor General of the United States — aposition he held for six years. He’d been appointed byPresident Lyndon B. Johnson during the last years of hisadministration, and in 1969 was reappointed by Presi-dent Richard M. Nixon. President Nixon for his secondterm, however, preferred as his S.G. a Yale law professor,

Mortimer M. Caplin is the founding member ofCaplin & Drysdale, Chartered, Washington. He servedas IRS commissioner from 1961 through 1964. Caplindelivered this report as the 13th Annual Erwin N.Griswold Lecture at the 2005 annual meeting of theAmerican College of Tax Counsel in San Diego.

In this report, Caplin addresses (1) Dean Griswold’seffect on the tax law, (2) the role of the U.S. Tax Court,(3) the role of the IRS, and (4) the tax lawyer’s role inthe way the American tax system works.

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Robert H. Bork, someone more closely in tune with hisphilosophy. Erwin Griswold’s duties ended in June 1973,at the close of the Supreme Court’s term, well in time toavoid the heavy lifting of Watergate and the ‘‘SaturdayNight Massacre,’’ although, he later said that he wouldnot have followed Solicitor General Bork in carrying outthe President’s order to fire Special Watergate ProsecutorArchibald Cox.

Shortly after leaving office, he joined Jones, Day,Reavis & Pogue as a partner and engaged in law practiceand bar activities for some 20 years, until his death in1994 at the age of 90. Erwin Griswold was honored manytimes over, not only for his innumerable contributions tothe law, but for ‘‘his moral courage and intellectualenergy . . . meeting the social responsibilities of the pro-fession.’’

III always suspected that any special feeling the Dean

may have had for me had roots in my strong backing ofhis plea for a single federal court of tax appeals — toresolve conflicts and provide ‘‘speedier final resolution oftax issues.’’ He observed, ‘‘The Supreme Court hates taxcases, and there is often no practical way to resolve suchconflicts’’; and he anguished over the practicing bar’sopposition to his proposal, convinced that ‘‘the realreason is that tax lawyers find it advantageous to haveuncertainty and delay’’ — a preference for forum-shopping, if you will. But in the end, in his 1992biography, Ould Fields, New Corne, he sounded a bit morehopeful: ‘‘Eventually, something along the lines proposedwill have to come as it makes no sense to have tax casesdecided by thirteen different courts of appeals, with noeffective guidance on most questions from the SupremeCourt.’’

One Supreme Court justice, who’d had hands-onexperience in tax administration, and well understoodweaknesses in our appellate review system, was formerJustice Robert H. Jackson. The Court’s most informedmember on taxation, he had previously served succes-sively as ‘‘General Counsel’’ of the Bureau of InternalRevenue (succeeding E. Barrett Prettyman), AssistantAttorney General in charge of the Tax Division, SolicitorGeneral, and then Attorney General of the United States.In 1943, in his famous Dobson opinion, Justice Jacksonmade a determined effort to strengthen the Tax Court’sstatus in the decisionmaking process so as to minimizeconflicts and attain a greater degree of uniformity. Tothose ends, he laid down a stringent standard in appel-late review of Tax Court decisions:

[W]hen the [appellate] court cannot separate theelements of a decision so as to identify a clear-cutmistake of law, the decision of the Tax Court muststand. . . . While its decisions may not be bindingprecedents for courts dealing with similar prob-lems, uniform administration would be promotedby conforming to them where possible.

The message was straightforward and seeminglyclear, but it didn’t cover district court decisions or thoseof the Court of Federal Claims. Also, other problems wereencountered by judges and members of the bar, anddissatisfaction was high. Ultimately that led to the 1948

statutory reversal of Dobson by enactment of the reviewstandard now in the Internal Revenue Code, whichrequires U.S. courts of appeals to review Tax Courtdecisions ‘‘in the same manner and to the same extent asdecisions of the district courts in civil actions triedwithout a jury.’’ And that’s where the situation lies today— save for those still aspiring, as Erwin Griswold did forthe rest of his life, for greater uniformity and earlierresolution of conflicts.

Justice Jackson never did change his view about thecritical importance of the Tax Court. In his 1952 dissent inArrowsmith v. Commissioner, he underscored this in strik-ingly poignant fashion, saying: ‘‘In spite of the gelding ofDobson v. Commissioner . . . by the recent revision of theJudicial Code . . . I still think the Tax Court is a morecompetent and steady influence toward a systematicbody of tax law than our sporadic omnipotence in a fieldbeset with invisible boomerangs.’’

Members of the tax bar readily endorse that strongvote of confidence in the role of the tax court. As ournationwide tax tribunal for over 80 years, it has servedeffectively and with distinction as our most importantcourt of original jurisdiction in tax cases.

IIIToday’s tax system has its genesis in World War II,

when income taxes rapidly expanded from a tax touchingthe better-off only, to a mass tax reaching out to theworkers of America. Revenue collection was turnedupside down with Beardsley Ruml’s ‘‘pay-as-you-go,’’collection-at-the-source, withholding and estimatedquarterly payments, and floods of paper filings. Commis-sioner Guy Helvering said it couldn’t be done. And, infact, the old Bureau of Internal Revenue, with its politi-cally appointed collectors of internal revenue, was notfully up to the task. Subcommittee hearings chaired byCongressman Cecil R. King, D-Calif., revealed incompe-tence, political influence and corruption, and directly ledto a total overhaul under President Harry Truman’s 1952Presidential Reorganization Plan. New district officesand intermediate regional offices replaced the old collec-tors’ offices; and, except for the commissioner and chiefcounsel, who still require presidential nomination andSenate confirmation, the entire staff was put under civilservice. The last step a year later was the official namechange to ‘‘Internal Revenue Service.’’

The new IRS made remarkableheadway, turning itself completelyaround by the end of the 1950s, and itwas not long before it was recognizedas one of the government’s leadingagencies.

The new IRS made remarkable headway, turning itselfcompletely around by the end of the 1950s, and it was notlong before it was recognized as one of the government’sleading agencies. In the early 1960s, new heights werereached through a fortunate confluence of events, strongWhite House endorsement, and unflagging budgetary

COMMENTARY / SPECIAL REPORT

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support. President John F. Kennedy had a special interestin tax law and tax administration and almost immedi-ately called on Congress for antiabuse tax legislation andstrengthening of tax law enforcement, including AttorneyGeneral Robert F. Kennedy’s drive against organizedcrime. Of key importance was the final congressionalgo-ahead for installing a nationwide automatic dataprocessing system (ADP), backed by approval of indi-vidual account numbers and a master file of taxpayershoused in a central national computer center. The IRShad entered the modern age. But it is that same ADPdesign, now badly out-of-date, that is still in use, albeitpatched with additions and alterations. And it is the direneed to modernize that 44-year-old system that is theIRS’s chief challenge today.

Starting in the 1970s, the IRS began to encounter itspresent serious difficulties. A series of complex legislativechanges, tightened budgets, an exploding workload, andexpensive failures to complete its ‘‘tax systems modern-ization’’ (TSM) project — all contributed to weakenedperformance and heightened congressional oversight. In1995 and 1996, Congress created the National Commis-sion on Restructuring the Internal Revenue Service ‘‘toreview the present practices of the IRS, and recommendhow to modernize and improve the efficiency and pro-ductivity of the IRS while improving taxpayer services.’’A year later, the commission issued its report, A Visionfor a New IRS, which led to the enactment of the InternalRevenue Service Restructuring and Reform Act of 1998(RRA 98).

The report centered chiefly on governance and mana-gerial type changes, including IRS modernization, apublicly controlled oversight board, a business-type com-missioner of internal revenue, electronic filing and apaperless tax system, taxpayer rights, and finally — andof primary importance — changing the IRS’s culture andmission so as to place emphasis on enhanced ‘‘customerservice’’ and functioning like ‘‘a first-rate financial insti-tution.’’ Congress was asked to do its part too: simplifiedtax legislation, complexity analyses, multiyear budget-ing, joint hearings, and coordinated reports of the differ-ent oversight committees. To the more sophisticated, thesuggestions to Congress appeared more aspirational thanrealistic.

The House largely followed the commission’s recom-mendations (H.R. 2676). But the legislation found itselfpending at a tumultuous time, when the air was filledwith words of U.S. senators — if you can believe it —like: ‘‘end the IRS as we know it,’’ ‘‘tear the IRS out by theroots,’’ ‘‘drive a stake in the heart of the corrupt culture atthe IRS,’’ and ‘‘stop a war on taxpayers.’’ At this point,Senator William V. Roth Jr., R-Del., Senate Finance Com-mittee chair, took over and ran a series of dramatic,highly televised hearings, carefully prepared by his staff,featuring a handful of allegedly abused taxpayers andIRS employees who gave testimony that shocked thenation. Never at the time did the IRS have the opportu-nity to tell its side of the story, nor was the testimonytested for accuracy or placed in proper context. Later,however, after enactment of RRA 98, court proceedingsand various government reports by the GAO and theTreasury Inspector General for Tax Administrationclearly established that much of the testimony was not

only misleading but false; the IRS may have mademistakes, but they were not malicious or systemic. Nu-merous corrective news stories began to appear withsharp headlines like the following: ‘‘IRS Abuse ChargesDiscredited’’; ‘‘Highly Publicized Horror Story That Ledto Curbs on IRS Quietly Unravels’’; ‘‘IRS Watchdog FindsComplaints Unfounded’’; ‘‘Court Is Asked to Block FalseComplaints Against IRS’’; ‘‘Secret GAO Report Is Latestto Discredit Roth’s IRS Hearings.’’ But publication cametoo late; the damage was already done.

Congress, the public, and ultimately the Clinton ad-ministration had all been outraged by the Senate testi-mony and, almost overnight, sweeping support wasgiven to Roth’s proposed highly stringent treatment ofthe IRS. His Senate version added some 100 new provi-sions to the House bill. Some are praiseworthy andreasonably protective of taxpayer rights, but others stepover the line, unduly micromanaging IRS daily opera-tions and laying the groundwork for serious delayingtactics by taxpayers and damage to the administrativeprocess. In the end, the legislation was adopted by anoverwhelming vote. One of the most criticized provisionsis the ‘‘10 Deadly Sins’’ sanction in section 1203 of RRA98. That peremptory discharge procedure, which directsthe commissioner to terminate an employee for any oneof the specified violations, is deeply disturbing to IRSpersonnel. Some hesitate to enforce the tax law becauseof possible unfair exposure to complaints by disgruntledtaxpayers. Both Commissioner Mark W. Everson andformer Commissioner Charles O. Rossotti have notedthat erratic impact and have requested modification. Inmy mind, there is little doubt that section 1203 should betotally repealed.

Commissioner Rossotti very ablycaptained the transition to the newculture.

Commissioner Rossotti very ably captained the tran-sition to the new culture. But with Congress’s continuingemphasis on the ‘‘customer service’’ aspect of tax admin-istration, it was not until his last years that the word‘‘enforcement’’ began to trickle out, along with warningsof the ‘‘continuing deterioration’’ and ‘‘dangerous down-trend in the tax system.’’ That shift in emphasis wasquickly hastened by new Commissioner Mark Everson,who early announced: ‘‘At the IRS our working equationis service plus enforcement equals compliance.’’ (This tome is the basic ‘‘S-E-C of taxation.’’) He underscoresrepeatedly the significant ‘‘diminution of resources’’; thecontinuing fall in audits, collection, and notices to non-filers; the 36 percent drop in enforcement personnel since1996; and, since 1998, the audit rate drop of 57 percent!

Perhaps of even greater importance is the negativeeffect that weakened enforcement has had on complianceand self-assessment. Commissioner Everson often quotesPresident Kennedy’s admonition: ‘‘Large continuedavoidance of tax on the part of some has a steadilydemoralizing effect on the compliance of others.’’ Indeed,the annual tax gap continues to grow: Last reported as a$311 billion tax loss each year — from underreporting,



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nonpayment, and nonfiling — new findings of a majorincrease are anticipated in the IRS study now underway.

With repeated annual deficits and a burgeoning na-tional debt, the commissioner recently confessed: ‘‘TheIRS, frankly speaking, needs to bring in more money tothe Treasury.’’ The White House had confirmed that bysupporting a 2005 budget increase, allocating to enforce-ment alone an increase of 11 percent. But that was not tobe. For in the recent cutback in the increase, HouseMajority Leader Tom DeLay, R-Texas, commented ratherimprudently: ‘‘I don’t shed any tears for the IRS. Ourpriority as far as the IRS is concerned is to put them outof business.’’ So much for the looming crisis in meetingthe revenue needs of our democracy!

The IRS’s final 2005 appropriation reflected hardly a 1percent increase — an overall grant of $10.3 billion,almost $400 million below the President’s request. Thattight squeeze tells clearly why the IRS went along withoutsourcing to private debt-collection agencies the collec-tion of some delinquent tax accounts. The statutoryauthorization to pay outsiders up to 25 percent of taxdebts collected is technically ‘‘off-book’’; and throughthat backdoor financing, the IRS’s appropriations takesno direct hit.

This then is the very serious state of affairs confrontingthose directly concerned with the fair and balancedadministration of our tax law.

IVThe proper functioning of our tax system is largely

dependent on the quality and responsible involvement ofwell-trained tax practitioners, primarily tax lawyers andtax accountants. Well over half the public seeks their helpfor tax advice and return preparation — inquiring, timeand again, about the ‘‘rules of the road,’’ what’s right andwhat’s wrong, what’s lawful and what’s not. The integ-rity and standards of those tax professionals serve as thenation’s guideposts, with direct impact on taxpayer com-pliance and the self-assessment concept itself. The signifi-cance of their good faith practices cannot be overstated.

The proper functioning of our taxsystem is largely dependent on thequality and responsible involvementof well-trained tax practitioners,primarily tax lawyers and taxaccountants.

Recent congressional and IRS investigations, however,have identified an alarming spread of extremely ques-tionable practices, some approaching outright fraud, by anumber of previously well-regarded tax practitioners.The Senate Finance Committee has zeroed in directly onpractitioners as a whole, emphasizing the ‘‘importantrole tax advisors play in our tax system.’’ CommitteeChair Charles Grassley, R-Iowa, caustically observed: ‘‘Atthe heart of every abusive tax shelter is a tax lawyer oraccountant.’’ In full agreement, Sen. Max Baucus,D-Mont., the committee’s ranking minority member,added: ‘‘Let’s stop these unsavory practices in their

tracks by restoring integrity and professionalism in thepractitioner community.’’ In their follow-up letter toTreasury Secretary John N. Snow, they called for rein-vigoration of the IRS’s Office of Professional Responsi-bility (OPR), for its proper funding, and for extension ofthe authority of its new head, Cono Namorato. Much hashappened since, legislatively and administratively.

Taking the lead, the American Jobs Creation Act of2004 greatly enhances OPR’s effectiveness through aseries of new provisions that expand Circular 230’s reach:(1) confirming authority to impose standards on taxshelter opinion writers, (2) clarifying authority to ‘‘cen-sure’’ practitioners, as well as to suspend or disbar them,(3) granting authority, for the first time, to imposemonetary penalties on individual practitioners, as well ason employers or entities for which they act, and (4)granting injunction authority, for the first time, to preventrecurrence of Circular 230 violations.

In turn, publication of Treasury’s long-awaited Circu-lar 230 amendments on tax shelter opinion-writing putsOPR’s momentum in high gear. The official releaseadvises that those ‘‘final regulations provide best prac-tices for all tax advisors, mandatory requirements forwritten advice that presents a greater potential for con-cern, and minimum standards for other advice.’’ Nodoubt is left, however, that the amendments’ underlyingintent is to ‘‘promote ethical practice,’’ ‘‘improve ethicalstandards,’’ and ‘‘restore and maintain public confidencein tax professionals.’’ Highlighted too is the caution that‘‘one of the IRS’ top four enforcement goals’’ is‘‘[e]nsuring that attorneys, accountants and other taxpractitioners adhere to professional standards and followthe law.’’

That is a harsh estimate of tax practitioners in general.As members of the profession of tax lawyers, it is difficultto ignore our collective responsibility to respond. Whatdo we do about it? Certainly the tax bar has not beenasleep. Both the ABA Tax Section and the AICPA sepa-rately have been working on standards of practice forover 40 years, and each has published a series of guidingprinciples which continue as works in progress. The issueremains, however, whether the tax bar has probed deeplyenough.

Have we been willing to grapple with more subtle,more difficult issues? Have we articulated what weregard as ‘‘best practices’’ for tax lawyers, keeping in mindthat Circular 230 applies to a broad range of ‘‘practitio-ners’’? Tax lawyers are clearly quite distinguishable fromother ‘‘practitioners’’ and, indeed, from lawyers in gen-eral. And it seems fair to ask: Which practices areacceptable to the tax bar, and which are not? At whatpoint does the tax bar regard tax advice or tax practice ascrossing the line? As ‘‘too aggressive’’? As ‘‘things thatare not done’’?

Those questions, of course, transcend the currentconcern with tax shelters only. It may not be long, in myview, before we will be asked to revisit a broaderquestion: ‘‘Whether, in a system that requires each tax-payer to self-assess the taxes that are legally due, a taxlawyer can properly advise a client that he or she maytake an undisclosed tax return position absent the law-yer’s good faith belief that the position is ‘more likelythan not’ correct?’’ In considering the issue some 20 years


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ago, ABA Formal Opinion 85-352 created as a moreflexible answer the ‘‘realistic possibility of success’’ test,which later became a touchstone used by Congress andTreasury in assessing certain penalties. In light of unac-ceptable developments since then, it would seem timelyfor the entire subject matter to undergo a thoroughreview.

Our profession of tax lawyers musttake the initiative and become moreintently involved — more proactiveand not simply defensive.

In his speech on the public influence of the bar,Supreme Court Chief Justice Harlan F. Stone addressedthe same theme of lawyers’ ethics regarding the greatWall Street stock market crash. Critical of ‘‘clever legaldevices,’’ and critical of lawyers having done ‘‘relativelyso little to remedy the evils of the investment market,’’ heobserved that ‘‘whatever standards of conduct in theperformance of its function the Bar consciously adoptsmust at once be reflected in the character of the world ofbusiness and finance.’’ In his view, ‘‘the possibilities of itsinfluence are almost beyond calculation’’ and he went onto advise, ‘‘It is needful that we look beyond the club ofthe policeman as a civilizing agency to the sanctions ofprofessional standards which condemn the doing of whatthe law has not yet forbidden.’’

The point is: Though we are a long-recognized profes-sion, allowed the privilege of autonomy and essentiallyself-regulation, no insurmountable barriers exist to pre-vent encroachment on this privilege, or even its end, ifour practices or standards are regarded as inadequate orunrealistic. Today, we already see a gradual erosionflowing from a series of new governmental rules — byCongress through, for example, the Internal RevenueCode or legislation like Sarbanes-Oxley, or by the SEC orPublic Company Accounting Oversight Board (‘‘Peeka-boo’’), or by Treasury through Circular 230 or otherregulations.

Our profession of tax lawyers must take the initiativeand become more intently involved — more proactiveand not simply defensive. Problems need to be identifiedand solutions developed by ourselves, and when neces-sary recommended for implementation by the bar ingeneral or by appropriate governmental bodies. We can-not wait for others to compel answers. Nor can we move

at the pace of the ALI project that required 13 years tocomplete a two-volume Restatement of the Law GoverningLawyers. Ours would naturally be more immediate intime and focus, and might well look to the leadership ofthe ABA Section on Taxation, this organization, theAmerican College of Tax Counsel, or some other con-cerned and qualified group.

As tax lawyers, we face many different responsibilitiesdaily — to our clients, to the profession, to the public, toourselves. How we maintain our own self-respect aslawyers, how we desire to be viewed by others, and howwe use our special skills to improve the nation’s revenueraising system — are all questions crossing our mindsevery day, some at times in conflict and in need ofbalancing as we confront our tasks. In that regard, DeanGriswold counseled us to preserve our ‘‘independence ofview’’ — separating our representation of clients fromour role as public citizens seeking to improve the func-tioning of government.

The one exemplar he acclaimed is Randolph E. Paul,Treasury’s general counsel and tax policy leader duringWorld War II, whom the Dean refers to as ‘‘one of theearly giants in the tax field.’’ Randolph, with whom Ipracticed during my beginning days as a lawyer, assertedthis individual independence throughout his entire ca-reer, while he developed a remarkable tax practice. In theclosing lines of his classic Taxation in the United States, hemakes these seminal observations on ‘‘the responsibilitiesof tax experts’’:

The most I can say is that I do not think surrenderneeds to be unconditional . . . I know tax adviserswho accomplish the double job of ably representingtheir clients and faithfully working for the taxsystem taxpayers deserve. . . . At another level Iventure the opinion that they lead a more comfort-able life than do many of their colleagues. Of onething I am very sure — that both taxpayers and thegovernment need many more of these independentadvisers.

Tonight this room is filled with many of these inde-pendent, responsible advisers — some surely to becomethe giants we will salute in the future. I am certain thattogether we will overcome our current challenge ‘‘torestore and maintain public confidence in tax profession-als.’’ At the same time, I have no doubt too that we willnot fail in our ongoing commitment to better the way inwhich our nation’s needs for revenue are fulfilled, fairlyand honorably.



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