It is sometimes said that a superhero like the DC Comics character Superman can be uninteresting because he is, for all practical purposes, indestructible.  Critics have said the knowledge that he will most likely win can make Superman's adventures monotonous.

A similar accusation could be leveled at the Federal Commissioner of Taxation (the flesh and bone personification of the ATO).  To most people, including a hefty majority of small and medium businesses, the Commissioner appear to be immune from defeat.   He...