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Manoj Viswanathan: The Professor Who Inspired Me to Love Tax

Posted on Sep. 6, 2021
[Editor's Note:

This article originally appeared in the September 6, 2021, issue of Tax Notes Federal.

]
Philip Wolf
Philip Wolf

Philip Wolf (@Wolf10Philip on Twitter; philip.wolf@law.nyu.edu) is pursuing an LLM in taxation at New York University School of Law and is a tax and corporate associate at Belcher, Smolen & Van Loo LLP.

In this article, Wolf interviews the professor that inspired him to pursue a career in tax.

Out of the thousands of different professions, how does one end up choosing tax? I can tell you exactly how it happened with me. During my second semester of law school, I was permitted to take one elective class. I selected basic income taxation. Although I knew nothing about the subject, I sensed it might somehow be helpful to my goal of starting a business one day. Little could I have imagined where the class would lead me!

In our first session, in walked the ebullient yet sincere professor, Manoj Viswanathan, or as he asked us students to call him, “Professor V.” Every lecture, Professor V. emphasized how everything we’d learn in his class would be practical and relevant in the real world. Time seemed to melt away in each Tuesday and Friday lecture, and I caught myself pondering what he’d said many hours after each class. It was Professor V.’s introductory tax class that would make me decide to change my career plans and become a tax lawyer.

I asked Professor V. how he decided to become a professor, and more importantly, a tax professor. I found his response to be unexpected, for his path was far from straightforward. He didn’t join the tax profession thinking he’d become a full-time academic, but he eventually realized that legal academia combined two of his passions: thinking about tax law’s role in shaping public policy and teaching students who were serious about learning.

He reached this conclusion by drawing on an eclectic group of life experiences, including working at a McDonald’s when he was young, studying science at the Massachusetts Institute of Technology, teaching high school physics at an Orthodox Jewish yeshiva, and working with the Department of the Treasury and then at a large law firm focusing on tax before deciding to teach.

I chatted on Zoom with Professor V., who was tucked away in what appeared to be his cozy home office.

Philip Wolf: What was your first memorable exposure to the U.S. tax system like?

Professor V.: When I was a kid, I worked at McDonald’s, making $4.50 an hour. My goal was to earn $300 and buy a camera. I’d even planned out how much time I’d need to reach that goal. So I was extremely shocked when I received my first paycheck and saw that there were these funny acronyms like “FICA” and things called “payroll taxes” and “income taxes” that were cutting into my precious camera fund. Kid version of me felt like I was being robbed! But underneath my childhood frustration, these acronyms also piqued my curiosity. Why was the government taking my money in the first place, and what was it being used for? Much later, this experience made me realize how tax law is arguably the most frequent law people deal with on an everyday basis. There are so many things implicating taxes that people aren’t aware of.

Wolf: How did you realize you wanted to work in the tax field?

Professor V.: I like to tell people that I didn’t find tax. Tax found me! Few undergrads start college thinking, “I want to be a tax lawyer,” and even fewer freshmen moving into their dorms run down the hallway telling people, “I’m gonna be a tax law professor!” As a physics and engineering double major at MIT, I certainly was no exception. Yet, MIT was helpful for getting me to understand my interests.

My years at MIT taught me that I liked pieces of a puzzle, and I liked applying mathematics to real-world phenomena. I also realized that I wanted to pursue more school, but I didn’t want a career in either of my majors. I desired to learn something more broadly applicable to society and humanity. Law school seemed to fit the bill. I had no idea exactly what I wanted to focus on when I entered law school, but I got lucky because I had an outstanding tax professor.

Wolf: What about your taxes class in particular attracted you to tax?

Professor V.: One of the aspects that fascinated me the most was how similar tax is to science. Both fields are highly technical. Unlike science, however, tax has a social policy element to it. Some fundamental questions of tax law are “Who should pay for government expenditures, and why?” and “What are the potential downsides of imposing these taxes?” These questions also implicitly ask if the current level of government expenditures is appropriate. These are really fascinating questions because they involve a combination of behavioral economics, technical rule writing, normative inquiry, and fiscal policy.

Wolf: How did you explore your interest in taxation from there?

Professor V.: I knew I wanted to learn more about tax. Thankfully, I was at NYU’s law school, so I got started on my LLM in taxation there. I also took part in the NYU Tax Policy Fellowship, where I spent a semester working for the U.S. Department of Treasury in the Office of Tax Policy. After finishing up my LLM, I went to work for a law firm. That experience was very beneficial to me. After all, private practice is where a lot of the complex issues we face in this country and in the world get mulled over.

Wolf: How did you make the jump to the world of academia?

Professor V.: Even though I liked law school, I didn’t see how it would turn into a career for me until I actually went into the practice of law. Learning about the complex tax issues faced in the field was important to me, and I gained a great deal of experience. Still, I kept coming back to how much I missed the public policy component of taxation. I found myself constantly thinking about what the law should be and not just how we might use the existing tax law to get better results for the client.

Although very valuable as a foundation, working in the field did not allow me to think about the normative questions raised in my law school tax classes, such as how big the earned income tax credit should be and why or the policy reasons for differing state and federal tax laws. So I transitioned into academia. It turned out to be perfect for me because I wanted to think and write about these issues and engage with students about them. That’s how I got to where I am now, at the University of California, Hastings College of the Law.

Wolf: Speaking of transitions, what was the biggest transition from tax practice to academia?

Professor V.: Being a tax professor is a totally different type of career. I work about the same now as I did at the law firm, but my work is more self-driven and less client/practice oriented. At the law firm, I was generally told what I had to get done and how. I didn’t have the flexibility to decide when, where, and how I’d do my work.

Now, even though I teach clinical courses and still represent clients, I don’t have the all-nighters that I used to spend at the firm. Instead, I have obligations to my research and to my students. On top of writing research papers, teaching tax classes, and being involved in various clinical courses, I just started teaching 1L contracts. It’s not a tax class, but I’m using what I’ve learned in my five years as a law professor to convey the same enthusiasm about learning that I feel for tax.

Wolf: Where did you realize you like teaching?

Professor V.: During my undergrad days at MIT, I taught high school physics part time at an Orthodox yeshiva just outside of Boston, of all places. Teaching several hours a day for two years made me realize I really liked teaching. For a time, I even thought about becoming a full-time high school teacher. Once I went to NYU and worked a bit, tax became the subject I wanted to teach.

Wolf: What is the relationship between your tax classes and your research?

Professor V.: Now that I’m a tax professor, I think of my job as being two separate jobs. The first job is doing tax research and thinking about interesting issues in tax law, especially those related to tax policy. The other job is teaching tax rules and theory to students. I’ve found there is no fine line between these two duties. What I teach can inform me what I want to research and vice versa. The two are often symbiotic.

Wolf: What’s your key for helping students with no tax background understand it?

Professor V.: The most common apprehension students have about taking tax is that they think it’s driven entirely by math. My response is that if you passed seventh grade and know how percentages work, you’ll be just fine. When teaching, I try to connect the statutes to real-life policy questions so that the law isn’t abstract. This builds a foundation upon which the more complex topics can be built. I’m also quite fortunate that my tax colleagues care deeply about teaching. My colleague Heather Field, who runs the UC Hastings Tax Concentration, is a paradigm of teaching excellence. I’ve learned a lot from simply talking with her about pedagogy.

Wolf: So what’s the secret sauce for inspiring people to be excited about tax?

Professor V.: The secret sauce is that professor Field and I don’t just throw the tax code at students. Instead, we show them how relevant the code is. Most people going into law school know, on a general level, things about criminal law and the Constitution. Some have even heard of torts. But very few know how tax works and that there is a complex, learnable mechanism behind how it works.

We get students excited about tax by pulling back the curtain. Most people have had jobs before enrolling in law school, and like me, they saw the weird tax acronyms on their paycheck. They didn’t know what the acronyms stood for, but they knew the acronyms meant that money was being taken away from them. We try to get students to understand why these things are in place and if they are good or not. Asking those questions gets people excited about tax.

Wolf: How did you figure out how to teach your first tax class?

Professor V.: I was lucky that my first tax class was with Lily Batchelder, who was recently nominated to be assistant secretary for tax policy in the Biden administration. I ended up becoming a teaching assistant for her. She got me interested and excited about tax, so I modeled my teaching and framework after her. I was also lucky to talk with Anne Alstott, who provided pointers about how to teach. Professor Field also helped me get an idea for what to cover and what not to cover. I’ve had to figure out how to teach the rest and to adjust it based on the students and if they’re understanding or not.

Wolf: What’s the biggest lesson you’ve learned about teaching students tax law?

Professor V.: I am fortunate that Hastings places such a high value on instruction. Research is certainly important, but I also have a moral and ethical duty to prioritize teaching. Students choose to go to law school because they hope their lives will be better (however measured) as a result. My goal is to help my students to make good decisions, become good lawyers, and get the career (and life!) that will actually bring them happiness.

Lawyers are notoriously unhappy in their careers. I want to make sure that at Hastings, students never regret having gone to law school or becoming tax lawyers or even just lawyers in general. Although I realize that some of the inspiration should come from the university, a lot is also from the professors. With that in mind, I’ve learned that being like that grumpy professor [Charles] Kingsfield from The Paper Chase just doesn’t work. It’s also not my personality. But, at the same time, you also can’t be completely lax. It’s a balance. So the lesson I’ve learned is that thinking about these questions is extremely important.

Conclusion

I am lucky to consider myself part of the tax community. This is in many ways thanks to Professor V. If it weren’t for Professor V. and his ability to inspire me to want to become a tax practitioner in his intro to taxation class, I would probably be in a completely different place in my career. He used an eclectic set of life experiences combined with innate intelligence and practicality to discover that his passion is teaching tax to students. I’m very glad he did.

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