Category Archives: TRUST FUND PENALTY

FILING BANKRUPTCY BEFORE SEEKING INNOCENT SPOUSE RELIEF ON IRS CLAIM ENDS IN DISMISSAL OF BANKRUPCY CASE AT REQUEST OF DEBTOR

Posted on August 3, 2013 by taxpenaltylawyer

Pearl Dwek filed for bankruptcy under Chapter 13.  Before the Court had confirmed her plan, she filed a motion to modify the stay to extend the period of her payment plan to allow her to proceed in U.S. Tax Court … Continue reading →

Posted in INNOCENT SPOUSE, IRS COLLECTIONS, STATUTE OF LIMITATIONS, TAX, TRUST FUND PENALTY | Tagged , , , , , , , , , | Leave a comment

IRS FIRST TIME ABATE POLICY PROVIDES PENALTY RELIEF IN CERTAIN SITUATIONS

Posted on June 1, 2013 by taxpenaltylawyer

The IRS today clarified its policy with regard to abatement of certain penalties for first time offenders.  The policy was modified to clarify that relief applies only where the taxpayer is current with all tax filings and tax payments. See IRM … Continue reading →

Posted in COMPLIANCE, DELINQUENT RETURN, EMPLOYMENT TAXES, IRS COLLECTIONS, POLICY, RETURNS, TAX, TRUST FUND PENALTY, UNFILED RETURNS | Tagged , , , , , , , | 6 Comments

FAILURE TO DEPOSIT EMPLOYMENT TAXES – TOUGH TIMES NOT REASONABLE CAUSE

Posted on March 1, 2011 by taxpenaltylawyer

There is a split among the federal Circuit Courts of Appeal whether there is a reasonable cause exception available to avoid the trust fund 100% penalty assessed against responsible persons. The 5th, 6th and 10th Circuits in addition to the Court of Claims … Continue reading →

Posted in TAX, TRUST FUND PENALTY, Uncategorized | Leave a comment