SOL on trust fund recovery assessments.
| Jurisdiction | United States |
| Author | Hudson, Boyd D. |
| Date | 01 May 1997 |
An employer is required to deposit with the Federal government the taxes withheld from its employees' wages. Should the employer fail to pay over such taxes, the IRS has the right, under Sec. 6672, to assess a penalty equal to the amount of taxes due against all persons considered responsible for the withholding and payment of taxes. This penalty is often called the"Trust Fund Recovery Penalty" or the "100% Penalty Tax."
The issue occasionally arises in cases under Sec. 6672 as to the application of the statute of limitations...
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