Tax Attorney for Payroll Tax Problems
Payroll tax problems are the most dangerous IRS issue a business owner can face. Personal liability is automatic.
When a business fails to deposit payroll taxes, the IRS views it as stealing from employees. The Trust Fund Recovery Penalty under IRC section 6672 makes any "responsible person" personally liable for 100% of the unpaid trust fund portion — the employee's share of Social Security, Medicare, and withheld income tax.
The IRS will assess the TFRP against owners, officers, managers, and anyone else with authority over financial decisions. This means the IRS can pursue your personal bank accounts, your home equity, your investment accounts — everything.
Defense Strategy
Defending against a TFRP assessment requires showing you weren't a "responsible person" (you didn't have check-signing authority or control over tax deposits) or you weren't "willful" (you didn't know the taxes were going unpaid or you were misled). These are legal defenses that require an attorney.
If your business has payroll tax problems, call immediately. The IRS assigns Revenue Officers to these cases and they move fast.
32 years of IRS experience. Free consultation. I will tell you exactly where you stand and what your options are.
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