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My name is Patrick Sheehan and I am a former IRS attorney what happens when the IRS comes after you related to your business taxes when a corporation has unpaid employment tax liability to the IRS and if that corporation can't pay the money fast enough the IRS might assert something called the trust fund recovery penalty against the owners the officers the shareholders the people who really run the business and by doing this they expand the number of people that they can collect from until they do this they can only collect from the business but when they expand it under the trust fund recovery penalty they can get the vice president the president the bookkeeper the Board of Directors the people who run the business when the IRS proposes to assess the trust fund recovery penalty against you they send a letter and the letter gives you 60 days to file a protest again deadlines are very very important you can't miss any deadlines because if you don't file a timely protest then the IRS is gonna say we were right and then they're gonna send a bill and then start collecting money from you even if you weren't really meaningfully involved in that business how do you defend against the trust fund recovery penalty there's two arguments that we make one is responsibility or willfulness responsibility means that you actually made the decisions that led to this unpaid tax liability you preferred to pay a creditor to keep the doors open instead of paying the money to the IRS a lot of people have someone who runs the business back in the office and someone who's out making the calls so the person out making the calls doesn't necessarily know what's going on back at the office the person in the office they're the ones who signed the checks decide who to pay decide not to pay the IRS the IRS will go after both of those people including the guy who was never in the office because he was still associated with this business in such a way that the IRS wants to collect the money from him we can defend against that the other argument we make is numerical accuracy IRS the number that you're seeking to collect is wrong and so we can make that argument for you well call us at 877 for IRS law you'll actually talk to a real lawyer who will answer your questions immediately call 877 for IRS law or visit our website at 877 for IRS law comm call us before the IRS calls you.