Tax Case Shows IRS' Dogged Pursuit Of Trust Fund Penalty

Law360, New York (November 10, 2016, 5:59 PM EST) -- A recent U.S. Tax Court case illustrates how aggressive the Internal Revenue Service (IRS) has become in using the trust fund recovery penalty (TFRP) to collect trust fund taxes. The taxpayer against whom the IRS assessed the TFRP was the wife of a passive investor of the employer corporation, but she was not an officer of the employer corporation, did not control its financial affairs, had no ownership interest, had no authority to hire and fire employees, and otherwise had little or no decision-making power beyond ministerial duties.

Notwithstanding the IRS's contentions to the contrary, the Tax Court held that the...

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