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Trust Fund Recovery Penalty (TFRP) Tax Returns

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

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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

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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

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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

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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

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