It is curious that Theobald on Wills makes no reference to any doctrine of “relating back”. Where does it come from? No tax statute. If your view of Hawley is correct then the assessment etc problems are real if infrequent. Tax law usually preserves delayed assessment/repayment rules to cope when charges are postponed and later reinstated. You do not comment on the difference between a specific legacy and Hawley’s contract as regards the tax point. Perhaps you see none
Jack Harper