Greetings! I am honored to deliver this year’s Griswold Lecture, though very sorry that we can’t gather in person to enjoy the usual post-lecture festivities. Hopefully that great tradition will resume again next year.
I’m especially pleased to join a distinguished group of prior honorees who include Judge Theodore Tannenwald (for whom I served as an early law clerk); my former law partners Mort Caplin and Randy Thrower; and several leaders of the tax bar who I’ve been privileged to know and work with over the years through the ABA Tax Section.
My topic today focuses broadly on tax education and, more specifically, upon the important role of tax practitioners as teachers of law school tax courses.
I offer my thoughts and observations on this subject from the perspective of one who has practiced tax law for five decades and taught at two leading law schools for almost 25 years. Well-educated and trained tax professionals are critically important to the effective implementation of our self-assessment tax system and the tax policies that underlie the tax laws. This topic is especially appropriate given Dean Griswold’s many contributions to legal scholarship and education.
My own plans to pursue a career in the tax field began to crystallize in 1960 when I entered Northwestern’s undergraduate business school. My dad was a Northwestern Law graduate with a general practice in Chicago. We had talked often about my becoming both a CPA and a lawyer—a professional combination then regarded in some circles as a “mother-in-law’s dream.”
My dad’s death toward the end of my sophomore year was a real shocker. Beyond the irreversible sorrow of losing a loved one, I deeply regret that I could no longer go to him as a trusted adviser and that he did not live to have the pleasure of knowing my wonderful future family.
During junior year I took a heavy load of accounting courses, including a not very inspiring basic federal income tax course taught from a Prentice-Hall handbook. The then “Big Eight” accounting firms were growing fast and on the prowl for new recruits, promising glorious career opportunities in public accounting.
Before making up my mind about law school, I spent part of my senior year in an internship program with the Chicago headquarters office of Arthur Andersen. It took me a while to get used to showing up to work each day in a pressed suit, starched white shirt, non-clip-on tie and, worst of all, a hat—but that garb certainly made me feel like a true professional.
My first assignment was to assist on the audit of a pig feed company located in a rural Iowa town that reminded me of the opening scene to each episode of Gunsmoke. The senior accountant on the job went back to Chicago after the first day, promising to return by week’s end. But like poor Charlie on the M.T.A., he never returned, instructing me each night by phone on what to do next. I ended up doing virtually the entire audit and ruined my best suit inspecting the physical inventories of some pretty disgusting stuff.
There actually were some things I liked about my Arthur Andersen experience, but in the end, I was convinced that a legal education would likely broaden my horizons and had no real downsides. So off to Northwestern Law School I went.
My law school class numbered around 160, only a small handful of whom had a professed interest in tax. The JD tax course offerings at Northwestern in those days were sparse: Basic Federal Income Tax, Estate and Gift Tax, and a Corporate Tax Seminar which used the original, and quite skinny, softbound edition of the already legendary Bittker & Eustice treatise. There was no Tax LLM program until many years later.
The then senior tax professor at Northwestern was Vance Kirby, a soft-spoken gentleman who had served at Treasury during the development and enactment of the 1954 Code. He taught the Corporate Tax Seminar and served as my faculty adviser for a law review comment on net operating loss carryovers and an independent study paper on an exempt organizations topic. To my great surprise, the NOL article was soon cited in a Third Circuit opinion; and the EO paper served as the inspiration for my first published article as a tax practitioner.
Professor Kirby urged me to consider beginning my tax career in Washington, D.C. and was instrumental in helping me secure a summer position at the IRS National Office. I worked there in a non-air-conditioned office, under the supervision of attorneys assigned to the old “Tax Court Division” of Chief Counsel. That summer I had the good fortune to meet Ted Tannenwald, who had joined the Tax Court in 1965. Again with the encouragement and support of Professor Kirby, I was delighted to accept Judge Tannenwald’s invitation to become his law clerk following graduation.
Clerking for a Tax Court Judge can be a great way to transition from the classroom to the much different world of law practice and billable hours. The opportunities to improve research and writing skills, and to evaluate trial testimony and documentary evidence in actual cases, are especially valuable. What’s more, by being exposed to work product of both taxpayer and government lawyers, law clerks can usually develop a comfortable level of confidence that their own performance as practitioners will measure up from a quality perspective.
Clerking for Ted Tannenwald was a terrific experience on all fronts. His door was always open to discuss pending cases or anything else that might be on your mind. He treated his clerks as co-equal colleagues in search of the “right” and “fair” disposition of the case at hand—always careful, in his own words, “to avoid making the courtroom a haven for the skillful liar or a quagmire in which the honest litigant is swallowed up.” He critiqued the draft opinions we prepared constructively and firmly, though always respectfully; and he was willing to change his mind on a tough issue if you could convincingly make the case for him to do so. It was a real privilege to work closely with Judge T and to have him as a teacher, mentor, and good friend for more than 30 years.
After clerking, and a less pleasurable stint with Uncle Sam, I began practicing with Arent Fox, then one of the fastest growing firms in Washington. In late 1971, Georgetown tax professor Peter Weidenbruch was appointed to the IRS National Office position of Associate Chief Counsel–Technical. As a result, the law school was in need of someone to teach his JD and Tax LLM corporate tax courses for the coming semester. Quite unexpectedly, I was offered that opportunity.
Apart from substitute teaching a couple of classes at Georgetown for Al Arent’s S corporations course, I had no real teaching experience. Nor had I yet had much practice experience in the corporate tax area but was definitely interested in that field.
So I took a deep breath, a leave of absence from the firm, and moved to an office at Georgetown, where I spent most waking hours during the next few weeks preparing my course materials and often wondering “What in the world have I gotten myself into?!”
It all worked out fine. I really loved teaching—despite the continuing pressure to stay at least a couple of weeks ahead of the class in order to learn the material. After returning to full-time practice, I continued to teach corporate tax courses at Georgetown as an adjunct until the early 80s, when I decided to focus my outside professional activities more on the Tax Section, speaking, and writing.
But I always expected that I would someday get back to teaching, and that finally happened in 2009, when I joined the tax faculty at Northwestern. I normally teach three corporate tax-related courses a year to both LLM and JD students. In addition, I bring government tax officials and other outside speakers to the law school, assist students in their job-seeking efforts, and participate in other tax program and law school activities.
I still love it—especially walking the familiar halls of my alma mater, getting to know students from many diverse backgrounds, and teaching from the same classrooms where I, and my dad before me, sat as law students.
There are approximately 200 accredited law schools in the United States. Virtually all offer a JD-level course on Basic Federal Income Taxation, though only rarely as a required course. Most also offer one or more additional JD tax courses as well, including, most commonly, corporate, partnerships, international, and estate and gift tax. Some also offer low-income taxpayer clinical opportunities. For those schools that have Tax LLM programs, JD students are generally permitted to enroll in many of the LLM courses; and at a number of schools, students can earn a combined JD/Tax LLM degree.
There currently are around 30 U.S. law schools with graduate tax programs through which full-time or part-time students can obtain an LLM. Some schools offer specialized Tax LLM programs in international tax (NYU, UC-Irvine, Michigan, and Florida), employee benefits (UIC-John Marshall), and estate planning (UIC-John Marshall, Golden Gate, and Miami). Michigan, Florida, and NYU also offer Doctor of Juridical Science (SJD) degree programs in tax.
Full-time Tax LLM students typically take a dozen or so courses over two semesters. In most of the LLM programs, certain core courses are required—including, for example, property transactions, corporate, partnerships, and international tax. Electives can be chosen from a wide range of specialty areas—including, among others, state and local tax, transfer pricing, tax treaties, wealth transfers, executive compensation, tax procedure, private equity, bankruptcy, exempt organizations, and tax controversies.
Some LLM programs offer mini courses on tax research, tax and financial accounting, and the use of Excel spreadsheets. Some also award “certificates” to students who take a slate of tax courses in specialized areas (e.g., corporate, international, private wealth) and achieve a prescribed GPA in those courses.
In recent years, several law schools have also begun to offer online Tax LLM courses and degrees. During the pandemic, of course, all or most law school classes are being taught remotely. But it is quite possible that many schools will decide to add online options to Tax LLM programs after in-person teaching resumes.
Certain of the Tax LLM programs are quite sizable in terms of the number of students and course offerings. Total full- and part-time enrollments at NYU and Georgetown typically exceed 200, with each currently offering 40–50 courses. Other sizable programs—with enrollments of 80–100 and 20–40 courses—include Florida, Boston University, Northwestern, San Diego, Denver, Loyola (Los Angeles), and Villanova.
Tax LLM programs generally rely heavily on tax practitioners as adjunct professors. As explained by Philip Postlewaite, Director of the Northwestern Tax Program, “adjuncts . . . are essential in ensuring that a wide range of topics are available to the students. Most programs have but a handful of residential faculty (usually five or less) who have JD teaching obligations as well. Thus, at best they could offer but ten courses.”
Charlene Luke, who heads the Tax LLM program at Florida, describes adjuncts as “invaluable,” especially as to teaching students “how to read, research, and write about . . . tax authorities . . . [and to] apply those authorities effectively to real-world situations.”
Adjuncts normally teach one course in their specialty area, typically once a week, and have few, if any, nonteaching obligations. Most also have busy full-time tax practices, but typically are good about communicating with students outside the classroom.
In addition to adjuncts, some schools hire, as nontenure track “Senior Lecturers” or “Professors of Practice,” seasoned tax lawyers who have recently retired or significantly cut back their practices. These teachers generally have a more substantial connection to the law school and its tax program. They typically teach both semesters, have an office and administrative support, attend faculty meetings, and participate in tax program activities or events. Though not obligated to publish, many have written articles in their specialty area and continue to do so while teaching.
Tax LLM programs are quite expensive, with the highest full-time tuition now pushing $70,000. While some scholarships are available, most students pay at or near full freight, and many are still carrying loan balances from their JD or undergrad educations.
A few students may be lucky enough to have at least part of their LLM studies underwritten by firms for which they have existing or waiting jobs. But virtually all other LLM students opt to spend another rigorous and costly year in school with a singular goal in mind: to acquire an academic credential that hopefully will enhance their ability to obtain desirable employment as a tax professional upon graduation.
In recent years, the job market for newly minted Tax LLMs has been generally good. Big Four accounting firms recruit heavily from Tax LLM programs to fill tax positions in field offices throughout the country and in their National Tax office as well.
By contrast, offers to graduating Tax LLMs by Big Law or other large law firms are harder to come by and generally are limited to students with very strong academic records. The interest level of mid-sized or smaller law firms tends to be higher. Moreover, an increasing number of students who started out at Big Four accounting firms have been able to lateral after two or more years into Big Law or other law firms.
Entry-level government jobs that may be an option for new Tax LLMs include honors-program positions with IRS Chief Counsel and the DOJ Tax Division. In addition, many Tax Court Judges prefer hiring Tax LLMs as law clerks.
A word of caution is in order, however, with respect to the COVID-related shift to online classes and working from home. Although a return to some semblance of normalcy is hopefully not too far off, the ultimate impact of the pandemic upon law school enrollments, employment opportunities, and the appetites of tax practitioners to continue or begin teaching gigs remains to be seen.
Assuming that a Tax LLM may in fact make many students more attractive in the job market, how important is that advanced degree from an educational standpoint? Does it in fact prepare students to “hit the ground running” and otherwise perform at a high level in their first job as a tax professional?
To be sure, there are many accomplished and successful tax lawyers in the country who did not obtain a Tax LLM. Some may have taken multiple JD tax courses and built up their tax knowledge through practice experience, on-the-job training, and self-study. That may well be a better route for those who cannot afford a costly LLM program or do not necessarily need the “resume boost” that an LLM degree can provide.
The decision as to which Tax LLM program to attend should be made in light of the applicant’s professional objectives, unique features of particular programs, and overall personal circumstances. It should not be based solely or mainly on a program’s U.S. News ranking. While some programs may generally be considered more prestigious than others, for students who regularly attend classes and conscientiously study the assigned course materials, the breadth and academic rigor of most Tax LLM programs should prove quite valuable as they embark upon and move forward in their tax careers.
Effectively teaching a law school course requires much work and a substantial time commitment. Among other responsibilities, the instructor must develop a course syllabus and materials; prepare thoroughly for each class; respond to student communications between classes; arrange for necessary make-up classes; and prepare and grade interim writing assignments and final exams. Adjuncts and other part-time instructors who have busy practices or other regular employment have to arrange their schedules so as to accommodate what is essentially a second job.
Teaching course content entails far more than lecturing on black letter principles or otherwise spouting all you know about the subject at hand. It’s very important to keep the class moving at a steady pace and to engage as many students as possible in dialog concerning substantive issues, as well as tax policy and practical considerations.
I normally try to focus class time on discussion problems and transactions diagrammed on PowerPoint slides or a whiteboard. The sharing of PowerPoint slides has proved to be especially effective in classes taught remotely. It is important that the slides be provided to the students in advance, so that they can be well prepared to discuss them in class.
After teaching the same course for a number of years, the material of course becomes quite familiar, and one might think that necessary preparation time is therefore reduced substantially. For me at least, that generally is not the case. Course materials must be updated each year for current developments—an exercise that can be particularly time consuming if pertinent new tax legislation has been enacted. Beyond that, I spend significant time thinking about how various aspects of my courses might be better presented to clarify or enhance the main points that I want to get across.
It is important that tax practitioners who teach draw on their practice experience in developing and presenting course content. Ron Pearlman, who taught full-time at Georgetown for 15 years after long stints in private practice and government service, sought in all of his courses
to expose the students to the real world by creating lawyer-client and practitioner-government representative situations in which to consider the substantive material, to raise ethical issues that [his] experience suggested likely would arise during their practice careers and to show them how a fuller understanding of the policy rationale of the statute could make them more effective advocates.
I, too, look for opportunities to inject practice-oriented exercises into my classes. As an example, for many years I have taught a course on spin-offs and other types of tax-free corporate separations under section 355. At the beginning of the course, I provide the students with a hypothetical Case Study that raises many section 355 issues that often arise in actual practice situations. As the course progresses, the Case Study serves as a frame of reference for class discussion of the various issues raised and preparation of a client memorandum or other written work product.
In most years, the class has been visited by a Service corporate tax official who holds mock National Office and Appeals conferences with teams of students. At each conference, the students present their positions on specific issues raised by the Case Study and respond to questions. I meet beforehand with the student teams to discuss how to conduct themselves and what to expect at the conferences.
The dialog between the students and the Service representative is normally quite robust. Simulated “real-world” experiences like these allow students to view their book learning from a different perspective—namely, as an advocate for a taxpayer client.
If properly focused, practitioner “war stories” can be effective vehicles for illustrating the dynamics of real-world tax practice. There’s one, in particular, that I like to use when teaching about tax-free reorganizations.
Back in the late ‘70s, I was involved in a matter in which (1) a closely-held corporation sold its business; (2) transferred the cash proceeds to a tax-exempt bond fund in exchange for fund shares; and (3) then distributed the fund shares to the shareholders in liquidation of the corporation. Some of you old-timers may remember this one, as it was quite controversial at the time. More easily than anticipated, we obtained a Private Letter Ruling (PLR) concluding that the transactions constituted a good “C” reorganization. Within a couple of weeks, news of the ruling had spread like wildfire, and new ruling requests were being filed for similar “cash reorganization” transactions.
After issuing only one more favorable PLR, the Service reversed gears and published two revenue rulings and a revenue procedure to the effect that these transactions did not qualify as good “reorganizations.” Treasury then proposed and ultimately finalized regulations announcing that the nonstatutory “continuity of business enterprise” (COBE) requirement for reorganization treatment could not be met absent the transfer of a “historic business” or a significant portion of the “historic business assets” of the acquired corporation. The mere transfer of recently generated cash from a sale of business assets clearly did not satisfy these new regulatory criteria.
This saga is valuable to my students in two respects. It gives them first-hand background as to what precipitated the “historic business” touchstone of the new regulations, a concept which arguably contradicts more expansive interpretations of the COBE requirement under prior rulings and case law. It also exemplifies how opportunities for creative tax planning tied to a literal reading of Code provisions can arise, but ultimately be thwarted through the regulatory process or other administrative action.
Another practice-oriented teaching drill that I like to use relates to the “step transaction” and “substance v. form” doctrines, which often rear their heads in a multitude of tax contexts. I do this by presenting multi-transaction hypotheticals and asking the students to prepare a short memo addressing (1) the tax consequences if each transaction is treated separately for tax purposes; (2) how the Service might seek to collapse or otherwise recharacterize the transactions; and (3) what the incentive would be for doing so. Repeatedly undertaking this type of analysis in the classroom will hopefully enable students to more readily identify and better evaluate step transaction risks in actual practice situations.
I also like to include selected published revenue rulings and sometimes PLRs in assigned course materials. Revenue rulings can be especially educational when they contain an extended discussion of the relevant legal principles and cited authorities.
Apart from their substantive content, assigned rulings also present an opportunity to pivot to a more general discussion of (1) the differences between published and private rulings; (2) the practicalities of deciding whether a PLR should be sought; and (3) the extent to which practitioners can derive comfort from existing PLRs in providing client advice on a similar situation.
Teaching methodologies and materials are by no means uniform. Pertinent provisions of the Code and Regulations are typically assigned but given varying degrees of emphasis in class discussion. Some teachers use casebooks or treatises, while others rely on their own handout or online materials. Some mainly lecture, while others regularly lob dreaded “cold calls” at students. Some use previously circulated PowerPoints as the main focus of class discussion, while others like to scribble on a whiteboard. And some conduct the entire class from a lectern or stool, while others like to cruise the room—in part to dissuade students from surfing the Web or checking their iPhones.
In short, teachers should adopt approaches and teaching tools with which they feel most comfortable—but always with the ultimate objective of providing maximum educational benefit to the students.
To my mind, the main benefit of a Tax LLM program is that it affords students an opportunity to systematically study a broad range of tax subjects, more than a few of which are likely to be quite relevant in their employment as tax professionals. They do this under the tutelage of knowledgeable tax professors, many of whom are also experienced practitioners, and some of whom may have served in high-level government tax positions as well.
Tax LLM students are deluged with heavy doses of assigned course materials over a relatively short period of time. Their ultimate goal should be to take away from each course a solid grasp of fundamentals and overriding tax policy themes, as well as whatever practical considerations the instructor can impart—and to avoid getting too bogged down in the technical weeds that all areas of the tax law inevitably contain. At the same time, students do need to gain at least a basic awareness of the kinds of issues that lurk in those weeds.
The practical aspects of teaching tax law cannot be over emphasized. Like most areas of the law, tax has important policy and doctrinal underpinnings. It is somewhat unique, however, in that the intricate web of statutory and regulatory rules permeates virtually every business and interpersonal context imaginable.
As expressed by Stef Tucker, who has taught courses on tax planning for real estate transactions for almost 50 years, “I believe the students should know that tax is a tail on every dog . . . it is the role of a teacher to help the student understand what the tax issues are, and for every problem to seek and assist the client to find a solution.”
Thus, in order to properly assess the impact of the “tax tail,” students need to know how important it is for tax lawyers to understand the broader context and specific objectives of what the client wants to do. And, as Tucker further notes, students should also be forewarned that “[i]t is never advisable to say to a client ‘no, you cannot do that,’” without suggesting alternatives that may be palatable, even if “not as attractive” from a tax standpoint.
In a 2010 article titled “Teaching International Taxation,” David Rosenbloom, a prominent international tax lawyer, former International Tax Counsel at Treasury, and Director of the NYU International Tax LLM Program, eloquently likens law school teaching to “acting,” as follows:
The classroom is a theater, and teaching a performance. The professor’s task is to gather and package difficult and far-flung subject matter and to present it in a shape that is accessible and interesting to students. In the best of circumstances there is a palpable connection between professor as master of ceremonies and students as participatory audience. On those occasions both students and professor leave class energized, with insights and questions and an eagerness to push beyond the discussion that has taken place.
Rosenbloom is quick to acknowledge that these fairy-tale endings do not always come to pass. He points, for example, to situations where the professor, although very familiar with the subject matter, has not adequately prepared for class. That, he says, “is a serious mistake because knowledge of the topic is definitely not a guarantee of classroom success.” He further counsels that professors should walk into the classroom with “a sense of timing, a feel for how available class time will be utilized . . . .”
I certainly don’t expect to win an Oscar or an Emmy for my teaching; but in a very real sense I do feel like I’m “on stage” when in the classroom, and that the substantial time I spend preparing for each class is very much like a “rehearsal.” I have a great sense of exhilaration when I know that a class has gone well; and when it doesn’t, that always motivates me to do better the next time.
No matter how thorough their preparation or well organized their presentation, teachers need to recognize that not all classes will come across as extra-base hits. Where strikeouts or mediocre performance occur, the professor needs to be able to nimbly switch gears and meet the added and often difficult challenge of getting things back on track.
In all events, it’s very important to conduct classes in a nonintimidating manner, so as to build rapport with the students. The teacher should strive to leave the students feeling that you really do know your stuff and are trying your best to help them grasp the difficult concepts and issues that the tax laws often present.
Tax professors who have spent many years in private practice and, like David Rosenbloom, in government service as well, add a special dimension to the student experience. Among others who fit this mold are Ron Pearlman (former Treasury Assistant Secretary for Tax Policy and head of the Joint Tax Committee; Washington University, Virginia, Harvard, and Georgetown); Carr Ferguson (former Tax Division Assistant Attorney General; NYU, Iowa, Stanford, and San Diego); Steve Shay (former Treasury Deputy Assistant Secretary for International Tax Affairs; Harvard and Boston College); Robert Wootton (former Treasury Tax Legislative Counsel; Northwestern); and Eric Solomon (former Assistant Secretary for Tax Policy and IRS Assistant Chief Counsel (Corporate); Georgetown). As well put by Solomon:
The combination of government service and private practice has given me a perspective that allows me to see both sides of an issue. The tax law is often ambiguous, and often both sides have merit. I try to apply this balance in my teaching. In addition, government service taught me to understand more than just the rules, but the policy underlying them, as well as U.S. and international tax policy on a broader scope, which I did not focus on or appreciate in my private practice. In my teaching I want my students to understand the policy and not just the rules. By understanding the underlying policy, the students can understand the rules better.
Career counseling is another area in which practitioner tax professors can be of great value to students. Each year I give a talk to Northwestern’s incoming Tax LLM class entitled “So You Want to Be a Tax Lawyer?” In part it’s a pep talk, explaining why tax really is a great area of law practice. But the main thrust is to describe private sector and governmental opportunities that exist in the tax field, and to offer my take on various questions commonly of interest to emerging tax professionals—for example, law firms versus accounting firms; big firms versus small firms; IRS Chief Counsel and DOJ Tax Division positions; Tax Court clerkships; planning versus controversy practice; and “hot” areas of tax practice.
Throughout the year I talk individually with many students about potential areas of practice, as well as specific job opportunities that they may be considering. To the extent I feel comfortable doing so, I write letters of recommendation and contact, on their behalf, persons in law firms, accounting firms, and government tax positions with whom I have close professional or personal relationships. Every once in a while these efforts help to strike pay dirt, which makes me almost as happy as the newly employed student!
So why is it that so many busy, successful tax lawyers have decided to fill their plates even further with teaching responsibilities? Why don’t they instead bill more hours, retire altogether, hit the beach more often, or try to improve their golf games?
In an admittedly limited and informal poll of several well-known tax lawyers who have taught both during and after their practice years, I asked “Why do you teach?” Listed below are some soundbites from responses:
My own reasons for wanting to teach are largely similar. Teaching corporate tax courses requires that I comprehensively study and keep up with developments in an important area of the tax law that I have specialized in through most of my practice career. I feel certain that the discipline of doing that has made me a better practitioner and that learning how best to present my tax knowledge to students has made me a better communicator with clients, colleagues, and others.
More broadly, I have come to realize over the years that teaching and counseling would-be tax lawyers allows me to help perpetuate the excellence and collegiality of a profession that plays a crucial role in helping to drive the engine of our nation’s economy and that has been very good to me personally throughout my career. It is, indeed, a very meaningful way to “give back.”
In closing, let me leave you with this simple message: Teaching tax law is a challenging and rewarding calling. So is practicing tax law. Putting the two together creates a valuable educational resource—a precious commodity that needs to be nurtured and perpetuated by existing and future generations of tax professionals.
For those currently teaching law school tax courses, I urge you to continue doing so for as long as the spirit moves you; and I hope that at least some of my observations today prove helpful in connection with your teaching endeavors.
Those of you now on the “back nine” of long practice careers are probably thinking about how to fill the next chapters. If you’re looking for new forms of mental stimulation and want to keep connected to the wonderful world of tax, teaching may be a great way to do that.
And for those who are still on the “front nine,” and can muster the time and energy to do something “extra,” consider seeking out available teaching opportunities and give it a try. I think you’ll be glad you did!
Thanks for listening!
The very helpful research assistance of Despena Saramadis, a 2020 Northwestern Tax LLM, is gratefully acknowledged.
