Re. executors of wills: "The effect of the personal liability provision is, crudely put, to terrorize personal representatives into ensuring that they do not overlook their obligation to file tax returns on behalf of an estate..."
Later: "In some circumstances, it may be better not to invite a taxing authority to take a second kick at the cat but rather (to mix metaphors) to let a sleeping dog lie."
Later: "In some circumstances, it may be better not to invite a taxing authority to take a second kick at the cat but rather (to mix metaphors) to let a sleeping dog lie."