October 2, 2012
Trust fund recovery penalty, also called CIVPEN on a Federal Tax Lien, may be uncollectible
Internal Revenue Code Section 6672 authorizes the IRS to assess and to collect personally from the “responsible person” when employment taxes are not paid over to the IRS. A Revenue Officer conducts an interview on FORM 4180 to determine liability. The factors to make a “responsible person” finding include whether…
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