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Trust Fund Recovery Penalty (TFRP)

Rivkin Radler LLP

Trust Fund Recovery Penalty & The Closely Held Business

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Depending upon what you read or, perhaps more accurately, depending upon how much you believe of what you read, you may be aware that many closely held businesses are concerned about their future. Most of these survived...more

Rivkin Radler LLP

The Trust Fund Penalty – Times May be Tough, But Don’t “Borrow” from Withheld Taxes

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It’s wonderful to be part of a successful business, especially in a strong economy. The owners are probably enjoying a more than just decent return on their investment and, in most cases, are getting along well enough. The...more

McGlinchey Stafford

Business Owners and Managers May Have Personal Liability for Unpaid Payroll Taxes and Not Know It

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A recent 9th Circuit Court of Appeals decision emphasizes again the potential exposure “responsible persons” have to personal liability for payroll taxes under the Trust Fund Recovery Penalty (TFRP) provisions of Section 6672...more

Pillsbury Winthrop Shaw Pittman LLP

Don’t Let Bank Uncertainty Delay Payroll: Considerations for Employers

With bank uncertainty making headlines, we answer employers’ most frequently asked questions about the consequences of payroll delays, strategies for mitigating risk and more. ...more

Freeman Law

Tax Court in Brief | Chavis v. Commissioner | Collection Due Process and Trust Fund Recovery Penalty

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Tax Litigation: The Week of June 13th, 2022, through June 17th, 2022 Phillips v. Comm’r, T.C. Memo. 2022-58 | June 13, 2022 | Lauber, J. | Dkt. No. 18553-21L Hatfield v. Comm’r, T.C. Memo. 2022-59 | June 13, 2022 | Lauber,...more

Freeman Law

Tax Court in Brief | Wolfson v. Commissioner | Collection Due Process and Review of Settlement Officer Performance of Duty

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Tax Litigation: The Week of May 2nd, 2022, through May 6th, 2022 DelPonte v. Comm’r, 158 T.C. No. 7 | May 5, 2022 | Holmes, J. | Dkt. Nos. 1144-05, 1334-06, 20679-09, 20680-09, 20681-09 Mighty v. Comm’r, TC Memo. 2022-44|...more

Freeman Law

Tax Court in Brief | Middleton v. Commissioner | Trust Fund Recovery Penalty Assessment and Collection Due Process

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Tax Litigation: The Week of April 4th, 2022, through April 8th, 2022 Scholz v. Comm’r, T.C. Summary Opinion 2022-5 |April 4, 2022 |Panuthos, J. | Dkt. No. 20743-19S Salter v. Comm’r, T.C. Memo. 2022-9 |April 5, 2022 |Lauber,...more

Freeman Law

Tax Court in Brief | Estate of Kazmi v. Commissioner | Trust Fund Penalties and CDP Hearings

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Tax Litigation:  The Week of February 28, 2022, through March 4, 2022 - Estate of Levine v. Comm’r, 158 T.C. No. 2 | February 28, 2022 | Holmes, J. | Dkt. No. 13370-13 - Shaddix v. Comm’r | TC Memo. 2022-11 | February 28,...more

Freeman Law

26 U.S.C. § 6672 – Failure to Collect and Pay Over Tax, or Attempt to Evade or Defeat Tax

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Also Referred to as Internal Revenue Code Section 6672; I.R.C. § 6672; Section 6672; Trust Fund Recovery Penalty - Background. In certain instances, the Internal Revenue Code (the “Code”) requires persons to withhold...more

Freeman Law

How to Designate an IRS Employment Tax Payment

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When a taxpayer makes a voluntary payment to the IRS, the taxpayer has the option to designate the application of the payment to certain periods and/or taxes. For example, if a corporation owes federal employment taxes and...more

Freeman Law

“Extreme Personal Hardship” Doesn’t Excuse Trust Fund Recovery Penalties

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Trust Fund Recovery Penalties (or TFRPs) refer to the tax penalties assessed against the responsible person(s) of a business (e.g., directors, officers, etc.) that failed to collect, account for, or pay over taxes on behalf...more

Freeman Law

Boo! — Personal Liability Exposure for Your Business’ State Taxes

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Halloween is just around the corner, and if you thought this year could not get any scarier, think again. Failure to remit your business’ taxes to the state may result in a personal visit by the Office of the Texas...more

Freeman Law

Taxpayer Wins Major Victory at Pleadings Stage on Trust Fund Recovery Penalty Case

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Employees are required to withhold federal income and social security taxes from the wages of their employees.  If an employer fails to do so, the government will often assert the trust fund recovery penalty (“TFRP”) against...more

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