A late 2008 Federal District Court case in California, United States v. Bevan1 has focused attention once again on the very different treatment of fiduciaries in terms of liability for unpaid federal taxes depending upon the nature of the fiduciary relationship. That case approved fiduciary liability for unpaid federal estate taxes while federal law specifically bars fiduciary liability for bankruptcy trustees and other bankruptcy fiduciaries acting under Title 11 of the United States Code.2 That inconsistency in treatment, based on Congressional enactments, continues to puzzle fiduciaries and others.