"In the field of revenue administration, there is no longer such a thing as a simple tax law. Complex problems require complex laws, and complex laws are made to protect all taxpayers alike."
When a state or local government provides for a general sales and use tax, it is assuming a heavy administrative responsibility. Such tax laws are deceptively simple. They are not easy to administer. Failure to recognize these facts has resulted all too often in disappointing revenue yields and widespread dissatisfaction among retailers and their customers.
No one really enjoys paying taxes. What may be merely mild distaste for the taxing process soon becomes active antipathy if the tax-payer has reason to believe that he is the object of discriminatory treatment. He expects the tax administrator to do whatever may be required to assure that others in like situation respond to their tax obligations in the same way that he does.
Dixwell L. Pierce,
Administration and Collection Problems,
9 Vanderbilt Law Review
Available at: https://scholarship.law.vanderbilt.edu/vlr/vol9/iss2/7