Primary practice
Payroll tax cases carry two threats at once — the business liability and the personal Trust Fund Recovery Penalty. I take both seriously from day one.
Missed or partial federal tax deposits and the cascade that follows.
Quarterly employment tax exposure across open and closed periods.
Personal assessment of the trust-fund portion under IRC §6672.
Preparation and representation during the responsible-person interview.
Direct engagement with the officer assigned to your case.
Handling both cases as one coordinated strategy.
Bank levies, accounts-receivable levies, and Notice of Federal Tax Lien.
Timely protests and appeals of proposed personal assessments.
Current deposits and filings while we pursue a resolution.