Trust Fund Recovery Penalty Defense Attorney in Novi

Employers are required to withhold federal income and FICA taxes from employees' wages. These are trust fund taxes, which are held by the government until paid. When a business fails to send these withheld taxes, the IRS can pursue individuals—not just the company—for the full amount. The penalty can reach into the hundreds of thousands of dollars.

You may be at risk if you:

• Had signing authority over the business bank account
• Held a title like officer, director, or manager
• Managed payroll or signed checks

The IRS often deems several people in the business as responsible. Do not assume someone else will handle it. The IRS will keep pushing until someone pays.

Challenging “Responsible Person” Status

The IRS must prove you had real control over payroll taxes. We dig into the facts: Who signed the checks, who made the decisions, and who actually handled payroll? The answers to these questions will help us build a case to show you were not responsible under the law.

Contesting “Willfulness”

The penalty only applies if the failure to pay was willful. Maybe you were kept in the dark. Maybe you were following orders. We gather evidence to show you did not intentionally fail to pay trust fund taxes.

Responding to IRS Notices and Appeals

If you receive a proposed TFRP assessment, time is short. We respond quickly, file formal protests, and present your case to the IRS appeals officer. This is your chance to resolve the issue before it becomes final. We know how to deal with IRS offices and revenue officers, and we do it on your behalf.

Negotiating Payment and Relief

If the IRS proves you are responsible, we can still help. We can negotiate an installment agreement, and often times find a way for you to pay less than the full liability. 

Litigation in US Tax Court

If we cannot resolve your case in IRS Appeals, we are prepared to proceed to tax court. Our attorneys have represented clients in complex tax litigation, and are always focused on protecting your assets and your future.

The IRS moves quickly to collect unpaid payroll taxes. The longer you wait, the more aggressive their collection actions become.

If you have received a trust fund recovery penalty notice or are concerned about payroll tax issues, please call us at (248) 262-3400. We will review your case, explain your options, and start building your defense today.