Tax Counsel III, California Franchise Tax Board
Area of Practice: Tax Law
Natasha Page's legal career came about almost by accident. Through college, three years of engineering school, and most of a subsequent position as a corporate secretary for an environmental engineering company, Ms. Page never imagined that she would one day be an attorney. The idea of practicing law came to her while she was sitting in a boardroom during negotiations for her employer's initial public offering (IPO). "I was very involved in the IPO, and I loved it," Ms. Page remembers, "As I sat in that boardroom, I knew I needed to become either the accountant or the attorney, and I decided on the attorney... I just needed to stay in the boardroom." While Ms. Page did eventually become an attorney, she didn't practice in boardrooms for long. Instead, she found her calling as a tax attorney at the California Franchise Tax Board.
When the environmental engineering company where she worked underwent a merger that would have forced her to relocate from Sacramento to San Diego, Ms. Page used the contacts she'd made as a corporate secretary to find a new position. "I called the attorney whom I'd met in the boardroom, and I asked if he knew anyone who needed someone like me," Ms. Page recalls, "And he said he needed someone like me." After that, the attorney hired her to be his paralegal.
Not long after she began her work as a paralegal, Ms. Page decided to take the leap to law school. It was a last-minute decision. "I applied to take the LSAT the week the application was due, got my LSAT results, applied to McGeorge immediately and got accepted three days before school started," she explains, "I worked as a paralegal every day and went to law school at night. It was absolutely the most brutal four years of my life. I just saw it as 'I can do anything for four years.'" Fortunately, Ms. Page received support from her fellow students in the evening program. "For four years, it was the same group. We all knew each other; we just all hung in there," she says, "I had a study group. There were four of us who met every weekend, and we became very close ... I still have good memories of our class." Ms. Page also took advantage of audio recordings of lectures, flash cards, and other study tools to make the most efficient use of her time in school. In the end, she graduated Order of the Coif and became an associate at the law firm where she worked as a paralegal before and during law school.
As an attorney, Ms. Page expected to continue working in the field of corporate law. She knew that tax was of paramount importance in business transactions, but her transition into the field of tax law was surprising even to her. "I was a business paralegal and a business attorney," Ms. Page explains, "I knew that every business transaction turned on tax, so I took a lot of tax [in law school], and I went to the Sacramento County Bar Association Tax Law Section meetings. One day somebody brought an application for a position with the Franchise Tax Board to a meeting. I picked it up. I was tired; as a first year associate, I was working all night long. I kind of sent it in on a whim." That whim turned out to be life-changing for Ms. Page. The Franchise Tax Board hired her, and she left her career as a business lawyer for a career as a tax attorney.
Ms. Page has been with the Franchise Tax Board for over thirteen years. The Board administers California's Personal Income Tax and Corporation Tax. As Ms. Page explains it, "We are an enforcement agency for the State of California, and we also work on education and outreach for tax law, so it's not all just enforcement. We also work on passing regulations and writing legislation." Ms. Page handles personal income tax appeals, specifically those involving the taxation of non-residents and Native Americans. These cases tend to be governed more by case law than by tax codes because they center on state sovereignty. "I do not deal with the [Tax] Code as much as my colleagues do…. I have found myself doing a lot more constitutional law," Ms. Page says, "I like it a lot. There's a lot more case research and research on the tax law in other states. I do a lot of reading, a lot of following up on what other states are doing. I don't do your typical tax practice, but it's very interesting."
As Ms. Page describes her job, "[It] typically occurs when someone has already gone through an audit, and then a protest, and is now appealing our action before the state Board of Equalization. I will write a brief and file it before the Board of Equalization, and the taxpayer and his or her representative will file their reply. I may or may not reply to that brief. Quite often, I will appear before the Board [of Equalization] at an administrative hearing." Additionally, Ms. Page sometimes assists the Attorney General's office in defending tax refund litigation suits in state court.
Although working for the State is less lucrative than working in private practice and budget cuts exacerbate the pressures placed upon state attorneys, Ms. Page enjoys her work at the Franchise Tax Board and the balance that it allows her. "The Franchise Tax Board has great hours, and it has three childcare centers right on the premises," Ms. Page says, "It's an excellent place to work—very supportive, very good benefits ... I sometimes feel like I am almost in academia because I don't have the pressure of being in private practice. I can withdraw a case if the tax answer is that I should withdraw a case. It's a good position to be in because I can do the research, and I can come up with the right answer, and I can act accordingly. That's really what I like best."
Ms. Page strongly recommends that law students prepare for practice by doing whatever they can to strengthen their writing skills. "I think the most valuable training every lawyer has to have is writing ... It's the crux of our job. We are writers," she emphasizes, "In the end, you have to convince the Board [of Equalization], the taxpayer, and the judge of your position. All the research means nothing if you can't convince the decision maker ... It's going to be your research and writing skills that make you a good lawyer." Ms. Page further notes that law students who want to work with tax should be familiar with both the Internal Revenue Code and the California Revenue and Taxation Code. An internship with the California Franchise Tax Board or the Board of Equalization can provide law students with valuable exposure to and practical experience with tax law, she explains — "Those are not paid internships, but they give [interns] real world experience. They're not just photocopying; they're doing research and writing briefs." For McGeorge students who want to connect with tax professionals, Ms. Page recommends joining the Sacramento County Bar Association Tax Law Section.
After law school, some attorneys gain experience with a state agency that handles taxation matters, such as the Franchise Tax Board, and then move on to positions with major law or accounting firms. Ms. Page, however, does not see herself leaving the Franchise Tax Board anytime soon. She observes, "My life kind of just goes where it goes. I never really planned to be an attorney. I never really planned to go to the Franchise Tax Board ... But I truly enjoy my job."