How does the IRS apply partial payments when a trust fund penalty has been assessed? Can the IRS apply payments to the trust fund portion of the employment taxes or must it apply the payment to the non-trust fund penalty portions? Trust Fund & Non-Trust Fund Tax Employers are generally required to withhold employment taxes… Continue reading Strategy for Paying Late Employment Taxes
Category: Trust Fund Penalties
Better than a Soap Opera? Trust Fund Tax Disputes
Businesses often succumb to the temptation to use taxes withheld from employees wages to manage cash flow problems. These “government loans” can prove to be quite costly. Hart v. Commissioner, 19120-12 provides an example. Facts & Procedural History The taxpayer worked for a real estate firm. The firm did not pay its payroll taxes. The… Continue reading Better than a Soap Opera? Trust Fund Tax Disputes