We represent clients from all U.S. and International locations regarding Federal Tax and California Issues.
If the IRS deems someone a responsible person and assesses the trust fund recovery penalty, the individual can appeal that determination and potentially fight the decision in court. Reviewing courts will consider several factors in determining who are responsible persons. Several of the most common factors are as follows:
Reviewing courts will weigh these and other relevant factors when assessing the validity of the IRS decision to consider an individual a responsible person.