Should the taxpayerwho may be experiencing financial hardship or
facing exceptional personal circumstances, always be compelled to pay
the full amount of her tax liability, no matter the consequences? And
what measures can or should the taxing authority take against a taxpayer
who cannot pay? Under what circumstances should tax debts be
forgiven in order to further greater societal and revenue goals? The
answers to these and other questions are of vital importance in analyzing
the law of tax collections. With a few notable exceptions,1
however,