News & Analysis as of

Trust Fund Recovery Penalty (TFRP) Income Taxes

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

Freeman Law on

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

Freeman Law on

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

Freeman Law on

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

Freeman Law on

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

Freeman Law on

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

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