Key words on that web page:
"Others purchasers, however,... perhaps have a higher threshold for risk."
Last year a fellow posted a message (perhaps in this forum, perhaps elsewhere) about the use tax on his boat. He'd been a NY resident paying his income taxes as a resident for many years, but purchased his boat and took posession of it and registered it in another state. After 20 years (literally) he brought it back to register and keep in NY. At which time the NYS authorities demanded use tax INCLUDING 20 YEARS OF PENALTIES AND INTEREST for failure to pay the use tax at the time of purchase.
No question of risk, because he'd been sure there was no risk 20 years ago. So, if you're relying on legal advice for tax matters, make sure the contract says that the advisor will be responsible for any penalties you may get hit with if they were wrong. They've usually got insurance to cover that. And if you're being clever on your own--remember, Ceasar tends to get upset about folks who think they don't have to render unto Caeser. No matter who the local Caeser is.