Journal of Information, Law and Technology

An Australasian Experience of the use of Selected Technologies in the Delivery of a Legal Education Program – some Lessons for Faculties and Educational Program Planners

Alan Smith(1) and Michael Walpole(2)
(1) Division of Distance and Continuing Education
Central Queensland University

(2) Faculty of Law
University of New South Wales

a.jsmith@cqu.edu.au and m.walpole@unsw.edu.au

This is a commentary published on: 30 October 1998 

Citation: Smith A. et al, 'An Australasian Experience of the use of Selected Technologies in the Delivery of a Legal Education Program – some Lessons for Faculties and Educational Program Planners', 1998 (3) The Journal of Information, Law and Technology (JILT). <http://www.law.warwick.ac.uk/jilt/98-3/smith.html>

Abstract
This paper describes and analyses an experience in the use of educational technologies in the teaching of a discipline based in Law. Through an examination of teaching practices and subject delivery in the Australian Taxation Studies Program (ATAX), the authors reflect on aspects which, with the benefit of hindsight, have proven successful as well as those that might been done differently. They also consider some of the options currently available for future delivery of the program and point to valuable lessons learned in the course of the development and implementation of ATAX which may assist others planning to develop programs of a similar nature.

1. The Impetus for an Australian Taxation Studies Program
During the last decade or more, the Australian taxation system has become increasingly complex and, perhaps, unwieldy. Writing in 1990, Grbich described the changes thus: 

‘Following the historic Tax Summit [in 1985], the Australian tax system has undergone the most thorough analysis and structural changes in half a century. As a result, the main structure of the Australian tax system has been modified significantly. The specific changes are important: 

•	a so-called ‘capital gains tax’ at normal tax rates (in fact this is a vastly extended income base); 
•	thorough restructuring of the corporate tax system; 
•	a significant roll-back of tax avoidance opportunities and tax shelters, particularly in fringe benefits and in attacks on tax evasion; 
•	a dramatic lowering of top marginal tax rates; 
•	a vigorous redirection of the administrative machinery in the Tax Office and tax collection procedures; and 
•	a new framework of tax in the off-shore area.’

The pace of change has slowed little since these words were written. In fact, it is about to accelerate with the current Tax Law Improvement Program which is busy rewriting the income tax statutes in a simpler style, and the evident intention of the current Federal Government to embark on major tax reform. The situation is further complicated by the fact that each of the six States and two Territories in Australia also has a tax base and distinct legislative power to tax for their own revenue. Their tax systems have also undergone change in recent years. 

It became evident that there was a critical need for widespread, high level, education in taxation throughout the taxation industry. This required a centre of excellence in Revenue Law to be established which could provide students genuine access to quality teaching and research no matter where they were located.

This need was also recognised by the revenue authority in Australia. During 1989 and 1990, the ATO undertook an extensive planning process to determine exactly what was needed and how it could best be developed and delivered. In 1991, following a rigorous public tendering process, a new entity, ATAX was established at the University of New South Wales (UNSW) under a contract between the university and the Australian Taxation Office (ATO). A third institution, Central Queensland University was contracted by UNSW to provide design and development expertise in distance education materials production and delivery.

One of the major tasks of the new entity was to immediately develop and deliver the type of comprehensive taxation education programs required by the ATO and tax professionals generally. It was (and still is) fully expected that any ATAX graduate should be able to work with equal facility in the Australian Taxation Office, state tax offices, professional practice or private enterprise.

In order to satisfy these high expectations, the various programs under the ATAX banner were developed after intensive consultation with a large range of experts and interests both in the accounting and legal professions and within UNSW. 

2. Degrees Offered and The Program of Study 
The ATAX Program Handbook describes the ATAX educational experience, as 

‘... intended to be an innovative synthesis of distance education and campus based study, designed to cater to the needs of decentralized students in the workforce and to deal with the problems of a demanding and rapidly changing discipline.’ 

In designing the delivery of ATAX programs, consideration has been given to the major theoretical bases upon which most successful (distance) education programs are based. These include what constitutes good teaching (Ramsden 1990), the value of dialogue (Holmberg 1989), and the three-dimensional theory of distance education with learner, dialogue and structure (Moore 1989) and the notion that deep learning occurs when concepts are reconstructed rather than simply accepted (Parer 1994).

The specific combination of methods used to achieve this ‘synthesis’ are described and discussed later in this paper.

Four courses of study are offered at undergraduate and postgraduate level. All ATAX courses are offered to most students on a part-time basis although full-time study is also possible. The Bachelor of Taxation (BTax) commenced in 1991. The, ATAX Program Handbook describes it as: 
  
‘...[a] purpose built degree designed to give a balanced education in the foundations of taxation and in the essential component disciplines. It focuses on developing competence in core tax subjects. It develops skills in accounting, law, economics, computer information systems and exposure to wider humanities issues.’

Because the BTax is a part-time degree it takes six years to complete. Its first graduates were in 1997. 

The three graduate courses commenced in 1992. A Graduate Diploma in Advanced Taxation (Grad Dip Advanced Tax), a Graduate Diploma in Taxation Studies (Grad Dip Tax Studies) and Master of Taxation (MTax) are offered. Entry depends on previous studies and experience. As the ATAX Program Handbook describes it: 
  
‘This postgraduate program emphasises self-directed research, including relevant research skills, and a critical understanding of the Australian Tax System.’

How these aims are achieved and whether more can be done to achieve them will be discussed later.

3. The Teacher/Student Interface at ATAX 
In this section, the components typical of the teacher/student interface at ATAX will be described and an attempt made to evaluate each component within the overall educational experience of each student. At this juncture, it is worth making the point that many aspects of the delivery strategy used at ATAX are not what might be termed 'cutting-edge technology'. It is more important for the most appropriate technologies to be integrated into the delivery strategy rather than the newest, or the most financially attractive options for the teaching institution. As Parer and Henri (1993) noted:

‘Technology must create environments that are rich in resources and empower participants to surpass their teaching’ (Parer and Henri, 1993). 

It is also extremely important for any program to employ educational technologies that are both readily available and accessible to all students if it is to have broad appeal. 

What follows therefore, demonstrates a heavy reliance on standard audio and visual media rather than some of the newer, more sophisticated educational technologies available. This is because these basic audio and visual media are most accessible to all of the ATAX student population, whereas access to the Internet is not nearly as widespread. In a sense, the most appropriate technology will often be ‘the lowest common denominator’. Having said this, it must be borne in mind that the lowest common denominator in technology is constantly changing, and the technology of 1998 will soon be replaced by other, more advanced technologies within the immediate future. 

3.1 Study Materials 
The fundamental medium of communication and the principal source of educational content for students is the package of materials designed for each subject taught in ATAX programs. 

All study materials are initially developed with input from instructional designers at Central Queensland University. The result is teaching materials which consistently attempt to engage students and provide various stimuli to learning. Students have been known to successfully pass subjects using only the study guide and without utilising any additional support measures. The materials also provide a solid base for students to undertake extra study and research in areas of specific interest. They provide an excellent and accessible resource for students and teachers in other subjects, for researchers who have access to the materials and for prospective students curious to know what will be expected of them, should they enrol in a particular subject in future. In addition, the fact that the study materials are distributed at the start of the session with a schedule of audio conferences, copies of the assignment questions, notices of all due dates, assessment criteria, mark allocations and word limit requirements means that students can plan their study prior to the commencement of each semester. There should be no surprises in store for them. As other forms of interaction with the lecturers are voluntary, the subject materials are intended to be self-directed, providing all essential content material and assessment activities. They are also intended to fulfil an additional need as a current technical resource for employees of the ATO, other than students, so it is paramount that the materials be accessible and readable for persons who are not expert in the particular field.

The frequent use of critical, reflective and problem-solving questions is an important characteristic of the way ATAX study guides are designed. The materials are characterised by frequent questions, problems and activities interspersed throughout each module of the study guide and opportunities for reflection at the end of each module. These features are intended to interest and engage the reader.

Another feature of the materials is the integration in the study guide of all necessary readings in the subject. This is sometimes done by means of a short quote, by means of more substantial pieces of text which have been reproduced, or by means of a link from the materials to one of the texts required to be purchased and used in conjunction with the study guide. One might wonder why it is that so much work is done for students in the provision of readings. The response to this is the reading materials are an essential part of the teaching and learning process and given the many students in remote locations across Australia, where access to adequate library resources is extremely difficult, issues involving access and equity are resolved by adopting this practice. 

In addition to purely print-based study materials, supplementary material such as computer discs, audio and videotapes accompany many subjects. Computer discs are used primarily in accounting and computer information systems subjects. Audio and videotapes are presently used primarily in the more traditional law subjects. Videotapes provide a visual stimulus for students who are finding learning at a distance difficult and who are used to actually seeing the lecturer present content. Videos are also used as a proxy for attendance at intensive face-to-face classes, (see 3.6) which are frequently held in the regional areas outside the major capital cities.

Where audio tapes are used in subjects, they are provided to every student in the subject as part of the study materials. They have proved to be an ideal means of providing access to expert opinion of visiting lecturers who are often asked to record a tape, or be recorded whilst being interviewed, when visiting ATAX. They are cheap to produce, easy to handle and few students find them inaccessible due to lack of technology. Many listen to these tapes on their car tape decks or personal music systems. Study thus becomes something that can be done on lengthy city commuting runs by city dwellers, or on long country drives by students who live or work in remote country areas. Both are typical of large numbers of ATAX students. Audio tapes have also been used in some instances to provide individual feed back to students on research papers and assignments. Audio conferences are also recorded on tape, made available to remote students and copies kept in all Learning Centres.

The use of comprehensive, print-based study materials, supplemented with portable forms of electronic media, has a number of advantages. 

The use of such comprehensive, print-based study materials is off-set by substantial production and distribution costs. High quality print materials are expensive in terms of the time involved in writing, editing and updating them to the highest standards of instructional design and content accuracy. The fact that Australian taxation law changes so frequently means that lead times for the final preparation of materials for printing and distribution are short and the printing of materials has to be done, sometimes literally, at the last minute. The heavy reliance on written materials also requires the institution to undertake a large scale distribution process at the start of each term in order to get usually two, sometimes more, sets of subject materials to about 1,200 students. Double handling of materials also occurs, of course, when students vary their enrolments. 

3.2 The Weekly Bulletin 
ATAX students do not gather around a notice board every day in the way that students in a conventional face-to-face program do. The original alternative means of communication at the commencement of the program was the ‘Weekly Fax’ (now called the ‘Weekly Bulletin’). The information included in the Weekly Bulletin might be of an administrative nature such as notice of dates and deadlines for variations of enrolment fee payment and so on. Academic information is also made available covering matters such as references to new cases, clarification of points raised in audio conference discussions, information regarding progress on the marking of assignments, names and contact details of tutors, topics for discussion in tutorials, and forthcoming regional classes or relevant conferences.

The Weekly Bulletin is now emailed and faxed to locations where students have such facilities. For large cohorts of students employed in one organisation, such as ATO offices, it makes more sense to send the Weekly Bulletin to a central point in the organisation and for it to be redistributed. This is the approach adopted in the ATO where the Weekly Bulletin is placed on a central electronic notice board so that all ATO students can read it directly at their work stations. Although this means of communication is both expensive and resource intensive, the Weekly Bulletin is a vital means of communication and strong emphasis is placed on the need for students to read it every week. 

3.3 Audio Conferencing 
Audio Conferencing has been used extensively in many successful programs to provide some measure of teacher – learner interaction. Hillman, Willis and Gunawardena (1994).  One of the guiding principles of ATAX program delivery is to produce educational transactions such as those described by Garrison. 

‘The educational transaction ideally is a collaborative process where dialogue and negotiation are possible and where students may actively validate their knowledge’ Garrison (1988).

Whereas ATAX print materials are the principal source of subject material for students, the principal teaching support tool is the audio conference. Each of the 26 ATAX Learning Centres is equipped with two or more conference telephones and venues for their use. These conference telephones are used by groups of students to join audio conferences for their subjects. A group of students (usually between 2–10 participants) at a Learning Centre will dial in at a prearranged time and date. The Sydney electronic bridge enables the lecturer in a studio in Sydney to hear and be heard by up to 36 conference telephones. 

Through a system of trial and error, it has been established that the maximum number for a viable, interactive, audio conference is about 35 students at six or seven locations. Thus, in large subjects many audio conferences are repeated several times in order to provide all students with an opportunity to join and participate in an audio conference. 

The audio conference is used to explore complex concepts and issues raised in the study guide in an effort to assist understanding. Although some basic protocols are necessary to ensure orderly participation, audio conferences are typically relaxed and genuinely interactive. Students are strongly encouraged to ask questions, raise relevant issues, share information and insights and conduct orderly debate with one another. 

The advantages of audio conferences are many. Because they are run frequently, audio conferences provide a degree of flexibility unlike most conventional lectures on a traditional campus. Students can arrange with the lecturer to attend an alternative audio conference other than their normally scheduled one thus enabling them to fit it in around constantly changing, busy work schedules. Although students are encouraged to physically attend Learning Centres to provide them with the opportunity to interact with other students and establish peer group communication, they can arrange to join the audio conference from their desks at work, or even from home. More importantly, this flexibility enables students far from Learning Centres to join a group of fellow students without incurring the significant opportunity cost involved in travel. Many a country solicitor has managed to upgrade his or her technical knowledge of taxation law by means of this facility. 

Audio conferences are also tape-recorded. Tapes are kept in Sydney and copies are distributed to ‘remote’ students who are unable to attend audio conferences. (Remote students are regarded as those located more than 300 km from a learning centre.) Students in the Learning Centres are also provided with tape recording facilities to enable them to keep a record of the audio conference. Many use a tape recording for revision purposes. Local tape recording of audio conferences also caters for students who have missed the conference for reasons of work or illness. With up to 50 conferences a week being taped, the copying and distribution of tapes is proving another challenge for ATAX administrative staff. Strict rules preventing abuse of the recording facility have to be maintained and regular ‘crack-downs’ are necessary to keep the demand for tapes, on spurious grounds, in check. 

Audio conferences however, are not without limitations. Lecturers need to carefully facilitate each group in order to stimulate genuine interaction and debate via this medium. Many academic staff prefer to deliver a traditional lecture rather than use the technology as means of ‘two-way communication’. Therefore new staff require, actual training not just in operational or technical aspects of audio conferencing, but also in teaching practices which complement the overall delivery strategy.

Technical hitches do occur. Sometimes lecturers have to cope with crossed lines, unsolicited voice mail interruptions and even, occasionally, piped music finding its way onto the telephone line from the PABX in a particular location. The Australian telephone infrastructure can also cause problems. Not all telephone cabling in Australia is optic fibre and some copper ‘landlines’ may be in the loop in a particular audio conference. The redirection of calls when there is congestion of lines can also affect performance. This can result in calls between Melbourne and Sydney (a distance of 1,000 km) being diverted via Perth (over 3,000 km away) which, subsequently, results in echo, interference and delay. Students also require some basic training in the optimum use of the conference phones in order to avoid feedback, extraneous noise, boom and crackle. 

The ATAX experience of audio conferencing has proven to be a cost effective and an educationally effective means of teaching which is most suited to a Socratic style discussion of the law. It also exemplifies Thompson’s observations in relation to spoken interaction:

‘Although print technology has dominated distance education, the existence of so many attempts to bring oral, group-based education to distance students bears testimony to a belief of the importance of spoken interaction…’ Thompson (1991).

3.4 Data Audio Conferences 
During 1995 ATAX built on the success of audio conferencing by introducing data audio conferencing facilities. Data audio conferences are scheduled for subjects when the lecturer believes students would benefit from a visual presentation of content in addition to synchronous interaction via telephone—such as in Accounting/Economic subjects where the working of involved formulas and calculation can be demonstrated. Based on technology adapted from dealing rooms in the financial sector, data audio conferences provide students in Learning Centres with a medium akin to a white board or overhead projector on which the teacher can display diagrams, charts, equations or text. The data ‘slides’ are displayed on the screen of a computer (PC) in the Learning Centre. The teacher’s PC and the students’ PCs are linked by modem and the interface between them is managed using designated software. 

The fact that the PCs are linked separately from the audio conference system means that voice and data are not required to pass via the same connection and this improves the communication time. Audio conferencing provides easy ‘real time’ voice communication. Data audio conferencing provides similar visual communication to supplement the voice communication. 

Data audio conferences are interactive, and the software allows the teacher to hand over control of an image on screen to another location. The students in that location may write (using a pen-like mouse that allows hand written text), type or highlight on the shared image. A useful feature of this technology is that each workstation can select a different ‘on screen’ text colour so that the particular contributor of a comment can be identified by the colour. What has been contributed can be seen in all locations within several seconds of being written or drawn. The teacher may, similarly, contribute to a slide by highlighting or adding text during the conference. This is particularly useful where the teacher wishes to build a picture, or emphasise points whilst the conference is in progress. Just as contributions to slides can be made during the conference, they can also be changed or erased whilst the conference is in progress. The slides used in a data audio conference can be saved and/or printed in the learning centres during or after the conference. 

Thus far this system has been used with limited success. There are inevitable lengthy delays in the transmission of data to the various Learning Centres, which means that verbal and visual communication is neither coordinated nor consistent.

The use of data audio conference equipment requires the observance of a number of protocols. While the software is not particularly complicated and uses legible and understandable windows and icons, substantial training is required for students to use the data audio conferencing equipment. Even the computer literate experience occasional difficulties with the software. The need to run a training session prior to a series of data audio conferences is also a constraint on the use of this technology in the program. This is compounded by the more extensive training required of staff teaching with the system. 

Neither of these constraints, however, compares with the immense difficulties originally encountered when the system was first installed. Incompatibility between PCs was a key obstacle in the successful utilisation of the technology. Various causes of incompatibility were: 
  
•	Incompatibility between modem cards in the various machines, principally those in the teachers' PCs and those in the Learning Centres; 
•	Communication errors arising from the different configurations to be found in the communicating PCs; 
•	Occasional bandwidth problems encountered in the national telephone network and the national network utilized by the Australian Taxation Office in certain locations. 

Many of these have been resolved but there is still some resentment on the part of students and staff which has stigmatised the data audio conference system. It may well be that now technology has advanced, an alternative visual interface can be developed, perhaps by using the, apparently, improved CUSeeMe software or similar options. 

3.5 Tutorials 
At the commencement of the ATAX program it was recognised that some students, especially new undergraduate students, might find it difficult to cope with what is essentially, distance education delivery of subject matter. Accordingly, a limited number of early undergraduate subjects, particularly Law subjects, provide students with the opportunity to attend tutorials. Normally these are of 90 minutes duration and usually three are offered per subject, per semester. Ideally, these are run by a tutor, hired by ATAX and held at a central location in a city or region which allows the maximum number of students to attend. Tutorials will not be arranged for locations with fewer than eight students. 

Where tutorials are not run face-to-face, an electronic alternative is provided. This may be a tutorial run from a Learning Centre, or from ATAX, using the audio conference bridge. On occasions, it will be a face-to-face tutorial that other students may join by means of the audio conference bridge or a telephone call. 

The value of face-to-face tutorials has been well documented. Good tutors can provide a more personal and interactive environment because of the smaller group situation. They may also provide students with an alternative to their usual lecturer. This is extremely valuable where their learning problems stem from a communication or personality problem related to the lecturer. 

At ATAX there are, however, problems with the running of tutorials. Where face-to-face tutorials are not offered and students attend electronic tutorials there is inevitably some question as to whether the alternative being provided is genuinely helpful. Furthermore, there is the apparent inequity for many students who, because they are enrolled in a sparsely populated location, find that no face-to-face tutor is provided for them, whilst their fellow students in the subject may have a face-to-face tutor because the numbers in that competing location justify the appointment of one. Such difficulties are dealt with as they arise and, if necessary, additional academic support is provided using whatever means available. 

Finally, there is the quality of the tutorial teaching itself. Given that there may be several tutors in several locations, active management and coordination of tutors is required to ensure consistent quality of delivery to all students. Fortunately, there have rarely been complaints about ATAX tutors but supervision of supplementary teaching staff will always be an issue to consider and monitor closely. The key to high quality tuition appears to be clear communication of the lecturer’s views and expectations and frequent opportunities for tutors to discuss the content with the lecturer. 

3.6 Postgraduate Classes 
Some face-to-face contact is provided for postgraduate students in the form of full day workshops held in their home locations by the lecturer of the subject. These Postgraduate Intensive Regional Classes (PIRCS) are run in all locations with more than ten students who have committed themselves to attending the PIRC. PIRCS are very popular with students. They are, however, extremely resource intensive and require extensive preparation and planning by the lecturer. They usually involve a series of case studies which are sent out to students in advance to allow preparation for the day. During the workshop the students are usually broken into groups and, after a preliminary lecture or other introduction by the lecturer, they are required to apply the law to the case study. These ‘breakout sessions’ are facilitated by the lecturer. Thereafter, the ‘breakout groups’ are reconvened in a plenary session and the whole class contributes their ideas to a solution of the problem in the case study. This is repeated for 4 to 6 case studies. At the end of the workshop written guides to the resolution of the case studies are distributed. Every effort is made to find additional resources to ensure that students in remote locations do not feel abandoned. 

If there is no PIRC in a particular location, alternative tuition is provided. This takes the form of a supplementary audio conference, covering the material dealt with in the PIRC and a video tape of the Sydney PIRC is distributed to all students who were unable to attend a PIRC. Even these video tapes are also welcomed and well received by students, although it is clear that students prefer face-to-face PIRCS. 

3.7 Other Teaching Resources 
ATAX is presently developing other teaching resources for students. What has been described thus far has concentrated on the formal delivery mechanisms associated with structured learning from materials provided. ATAX also provides students, especially postgraduate students, with the opportunity of self-directed study and research. All subjects taught at the Masters degree level require the completion of a research paper, and some Masters subjects are entirely research based. This means that the students in these subjects require access to good information resources.

3.8 The University of New South Wales Dial-Up Service and the Australasian Legal Information Institute. 
All students at the University of New South Wales, including ATAX students are entitled to make use of the University Dial-Up Service (UDUS). Details of this service can be found at http://www.disconnect.unsw.edu.au/misc/general.html. The service provides cheap access (at the highest rate - 70c per hour, plus telephone tolls) to the Home Page of UNSW and to the Library Catalogue and via links, to other libraries. This enables students to run some library searches from home or office. Access to UDUS provides students with access to the Internet and thus to the Australasian Legal Information Institute (AUSTLII) at <http://www.austlii.edu.au/>. AUSTLII is a joint project of the University of New South Wales and the University of Technology Sydney and is an extremely comprehensive, free, database of resources for legal study. It contains nearly all Australian legislation and law reports as well as useful links to government, educational and sundry relevant sites in Australia and elsewhere. 

The major bar to the widespread use of UDUS and the opportunities it affords is the fact that, even where students have the necessary technology, the UDUS service requires a telephone call in to the University server. For students in, for example, Perth, which is 3,278 km away from campus, the cost of a long distance call is discouraging. Some students overcome this problem through the use of an Internet Service Provider of their own. Equity issues, again, begin to creep in and it is the writer’s view that positive steps are required to ensure widespread access to the Internet for all ATAX students. At present the option being explored is the provision of a stand-alone PC with Internet access in every Learning Centre for students’ use. 

4. The Product of the ATAX Approach 
As mentioned earlier, the ATAX program has been operating since 1991 and has now produced graduates from all its programs. It is highly regarded by these in the tax industry not only as a distance education provider but more importantly, as a provider of the highest quality taxation research and expertise. It is the program of choice for staff of some of the major international professional consulting firms and it is the only university taxation program for which the ATO will now provide study support for its staff undertaking undergraduate or postgraduate education who enrol as students. 

ATAX has had the opportunity to stage several international conferences and it has consulted widely in its establishment and development. The result is that it has started to attract Australian students studying outside Australia, as well as some foreign students. Students study ATAX subjects in Papua New Guinea and in New Zealand, and further afield, in Singapore, Egypt, and Europe. Few of these constitute foreign students recruited overseas. Most are Australians who are overseas for various reasons and who have chosen to study Australian courses whilst away from home. 

5. Opportunities 
What does this suggest in terms of opportunities, which may exist for other projects for ATAX, and for other jurisdictions? It would appear that the ATAX model, appropriately adapted, lends itself to similar large scale projects. Without the constraint of having to move students around so that they can attend lectures and other activities on university premises, it is possible to provide high level legal education in a location, which is convenient to the students. It is possible to do so by a number of means. 

•	An Internet site might be used as a location for students to visit and collect messages, or even materials. 
•	They might also use the site to search the university’s resources. 
•	Interaction with teaching staff can be facilitated in a number of ways: 
•	visits by staff; 
•	contracting local staff; and better still 
•	interaction electronically, using a telephone system. 
•	In relation to the last option, even the cost of calls ought not to discourage the use of the telephone as a teaching medium. Discount providers already reduce the costs and such costs dwindle in significance when compared with the savings in infrastructure in not having teaching premises, and savings in opportunity costs and direct cost of travel. 
•	Modern technology now provides the opportunity to transmit sound and image quickly, clearly and reliably. This lends itself to centralising teaching and research resources and making them available to remote locations. The possibilities in legal education seem endless. A subject of value to international students such as jurisprudence, for example, or international law, could be offered at two or more institutions making use of the expert teacher at only one of them. The expert’s views could be made available to many more students in this way. 
•	Essential reading and other guides could be placed as a central resource on a server and accessed via the Internet. 

It must be accepted that such possibilities will not be automatically appropriate for all subjects. Only those of cross-jurisdictional value would suit this approach, yet the benefits would be considerable. 

6. Options for the Future 
After a successful period of establishment and rapid growth, ATAX has reached a point at which it must prepare itself for the next period of technological change. Readers of this paper will be aware of the vast change in technology that has taken place since ATAX was being planned in 1990. A number of options are being considered, some are already being implemented. 

6.1 Materials Distribution 
The issue of the cost of materials distribution has been the subject of review and the possibility of providing readings and materials in electronic format is being seriously investigated. The cost of producing and distributing materials on CD-ROM may be lower than producing and distributing them on paper, especially when courier charges and staffing costs are taken into account. This option assumes of course, that all students will have regular access to a PC with CD-ROM capabilities.

Some tax publishers in Australia are already offering customised packages of their own electronic format materials, which might be adapted for ATAX’s needs. It may not even be necessary to distribute CD-ROM materials in the conventional way as they may be provided online using a central server facility, or if call charges become an issue, a number of mirror sites around the country. A pilot project using tax material online has already been run in the Law School at UNSW. Electronic materials provided the added facility of hypertext links and, if appropriately designed, afford opportunities for even greater interactivity. 

The continued development of the ATAX Home Page on the Internet will eventually provide a central additional resource for ATAX students obviating the need to distribute the Weekly Bulletin and even removing the need (as suggested above) to distribute materials. It will also provide a central communication centre for students to communicate with one another as well as with the institution. 

6.2 Video Conferencing 
At the inception of ATAX it was believed that modern innovations in video conferencing provided the ideal means of reaching large numbers of students in distant and widely dispersed locations. This has not proved to be the case. At ATAX’s inception, and even now, video conferencing has proved expensive and difficult to arrange, requiring students to move to a video conferencing site. These costs have reduced, however, and further experiments have been run with video conferencing using the relatively inexpensive facilities of the Commonwealth Administrative Appeals Tribunal to run the PIRCs in the subject Tax Policy in the second half of 1997. Not all staff and students are convinced of the need for video conferencing now an effective audio conference format has become well established, but there can be no doubt that the visual component in ATAX conferences adds a valuable extra dimension. 

The falling cost of video conferencing may well make it more attractive within a few years. In addition improvements in CUSeeMe may provide the necessary visual link between students and teacher even more easily. Finally the Data audio conference infrastructure, which has already been established, ought not to be abandoned yet, as improvements to modem compatibility and telecommunications have been made and continue to be made. If anything, one of the challenges facing ATAX will be the choice of the right video technology to adopt in this rapidly changing area.

7. Conclusion 
ATAX has been an innovator in taxation education in Australia. It has shown what can be done given proper planning, resourcing and implementation. It has provided a unique educational and research experience for its students which might well serve as a model for British and Irish legal education. Indeed, any institution that seeks to combat the ‘tyranny of distance’ with a program designed to bring remote students together and to provide a consistent quality educational resource over a large distance could look to the experience of the ATAX Program and find ample food for thought. ATAX has been fortunate to have a committed industry partner in the ATO, particularly regarding access to that partner's learning locations and to the assistance of their staff. Without the commitment and continuing support of the ATO, ATAX’s story might have been very different. 

The success of ATAX is not attributable to any single technology used. Rather, it is the integration of components into an overall program delivery strategy and the commitment by all involved in the ATAX program that has made the difference. As Taylor, Lopez and Quadrelli (1996) stated:

‘We can learn to use technology in educationally appropriate ways in order to achieve a reform in the delivery of education. Or we can use technology to lengthen the reach of one-way transmission – doing more of the same, but in broadcast mode. … The difference lies in the values and principles that underlie the practices, and the understandings and skills that give rise to them.’  (Taylor, Lopez & Quadrelli, 1996, p.111)

This appraisal of the ATAX Program highlights a number of important issues for providers of law studies to consider in the development and delivery of courses. Above all else it should be remembered that:

‘Education must never be made secondary to the technology by which it is served. In both pedagogy and the means of delivery, there needs to be parallel value shifts: an increased focus on the learner rather than the teacher, on the user rather than the provider, on flexibility rather than rigidity, and on the individual rather than on the institution.’ (OLTC, 1997)

The ATAX experience has also demonstrated that careful planning, adequate resourcing and the ongoing commitment by staff will overcome most problems likely to impact on program development and delivery.

References
Garrison, D.R. 1988 ‘Andragogy, learner-centeredness and the educational transaction at a distance, Journal of Distance Education Vol. 3 No.2

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