What is the Trust Fund Recovery Penalty?

The Trust Fund Recovery Penalty (TFRP) is a tool the IRS uses to hold individuals personally accountable for withheld employment taxes a business failed to pay. If the IRS deems you a "responsible person", and you do nothing:

Your could face IRS liens and levies to recover the unpaid payroll taxes.
Your personal liability for the tax debt continues even if the company dissolves.
This tax problem could hinder your ability to provide for yourself and your loved ones.

How Our Tax Attorneys Defend You

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.