To the Editor:
I was amused by Sheldon Banoff's letter, "Is Lee Sheppard Suffering
From P---- Envy?" Tax Notes, Apr. 24, 2000, p. 577. Mr. Banoff is right
that, whatever her views may be, Lee Sheppard is masterful at stirring
up controversy and masterful at expressive writing. Since she combines
these skills, she is quite quotable. I have my own list of Lee Sheppard
quotes, collected in my one face-to- face Lee Sheppard encounter at the
USC Tax Institute a couple of months ago. Before many witnesses, while
taking on "corporate tax shelters," Lee said:
"What's going on is not tax planning, because there is no such thing
as tax planning."
"We as lawyers should be ashamed that we have to write an economic
substance law into the tax law."
"You can buy any legal opinion you want."
"And now, for a less popular suggestion of mine..."
At this point in my quote scribbling I frankly ran out of steam,
but I think Lee's last (supposedly even more unpopular suggestion) had
something to do with attempting to import the tort concept of attractive
nuisance into the tax law.
I'm still speechless (but Lee decidedly isn't). What an asset she
is to Tax Analysts, even if I disagree with just about everything she says!
Kind regards,
Rob Wood
More Praise for Lee Sheppard, Vol. 87, No. 7, Tax Notes (May
15, 2000), p. 1007.
MORE PRIASE FOR LEE SHEPPARD
San Francisco
April 27, 2000