gollumProfessor Rob Morrow has an interesting way of teaching, to say the least. Instead of focusing solely on a barrage of appellate case law in his mandatory Federal Income Tax class, he strategically ties his lectures to popular culture. For example, Gandalf, Gollum and the Eye of Sauron—popular characters in The Lord of the Rings trilogy—are simply metaphors for various components of tax law.

Professor Morrow explains the cash method of paying taxes with his typically colorful flair. “Money is income when this raw beast actually feels the coins in its primal paw; expenditures are made only when the beast can see that it has given the coins away,” says Professor Morrow, quoting from a famous 1984 11th Circuit case. This method is analogous to the character Gollum who becomes insatiable unless “the precious” is in his possession. The second method of paying taxes is the accrual method, which moves in “a mystical wizard-like realm.” “The visionary prophet recognizes the impact of the future on the present, and with grave foreboding or ecstatic anticipation, announces the world to be,” explains Professor Morrow. Yes, the accrual method represents Gandalf and his ability to comprehend the impact of a future transaction (like recognizing income on an invoice even before the customer has paid it).

But wait—that’s not all. When it comes to paying taxes, “the ultimate arbiter stands to the side, shifting its eyes uneasily from the one being to the other.” Either method is acceptable because the Eye of Sauron (the IRS) “knows that man must generally choose his own way.” Therefore, it leaves to the Taxpayer the original choice of which accounting method to use.

So in conclusion, if there were one Federal Income Tax class to rule them all—this would be the one.


Professor MorrowProfessor Rob Morrow teaches Federal Income Tax (J.D.), Federal Income Tax for LLMs, Taxation of Business Organizations, Partnership Taxation, S Corporations, and Closely-held Business Tax Planning at Chapman University School of Law. Click here to read more.