We are an “affordable professional tax firm” with an expertise in IRS tax matters including trust fund help an expert representation. Call us before the 4180 interview.
As a former IRS agent in teaching instructor, I have worked hundreds and hundreds of cases involving trust fund taxes both the assessments, the appeals and the collections.I cannot possibly tell you how many form 4180’s I have filled out.
I know all the inner workings of the internal revenue services, all their methodologies, all their settlements and their exact thought processes of the trust fund recovery penalty, 4180 and the assessments thereafter.
Being a former IRS teaching instructor I taught this program to new IRS employees.
There are many trick questions on form 4180.
Any taxpayer going to this process should seek professional representation unless this is a very simple case and you can be rest assured IRS will not even think about holding you as a responsible person.
Call us today for a free initial tax consultation and I will walk you through the process of getting the best possible result giving the facts and circumstances of your case.
I would caution any taxpayer never give IRS a form 4180 unless they have had a true professional review the answers.
That form is one of the main forms that IRS uses to make a determination the trust fund recovery penalty.
You do not want to do this by yourself because of damaging result the trust fund penalty will have on your life.
This assessment will be individually made against you and IRS has the fertile arsenal to collect the taxes. If possible you want to file an appeal if you have a suitable case.
Filing an appeal will delay the assessment of this case and make sure more importantly that IRS finds responsibility against other parties and the cases all come out at the same time for collection. It also stops the interest from running on this tax debt until an assessment is actually made.
Some cases are very simple and taxpayers can represent themselves.
As a general rule you should know that the IRS wants to make everybody responsible that they can so they can fully collect the tax. IRS will do their best to force the issue on trust fund recovery penalties.
Their philosophy, set up everybody for this tax, the more responsible, the merrier.
Call us today and we will review your case and let you know exactly where you stand and let you know how to get the best possible results.
How IRS will Work the Case
1. Regardless of the amount of the trust fund, revenue officers will make a reasonable attempt to collect the entire liability in full. IRS will conduct a full asset search of the company including bank statements reviewing individual and personal and corporate income tax returns and do a full asset search.
2. Potential for additional liabilities from unfiled returns, IRS will conduct a full compliance check on both business and individuals.
3. IRS will conduct the Taxpayer’s history of non-compliance that extends beyond the open balance due accounts.
4. Responsible person’s history of employment tax non-compliance. IRS will want to know if you are repeat offender. Sometimes repeat offenders are refer to the criminal investigation unit for criminal enforcement.
5. A seasoned revenue officer can get in and out of these cases real quick. Having a seasoned tax professional can get you the very best possible tax result.
The IRS uses a number of determining factors to find out who is responsible for the trust fund penalties. See below some of the determining factors.
Some of the determining factors used to find individuals liable for this penalty are as follows:
1. Which individuals determine financial policy?
2. Which individuals authorize payment of bills?
3. Which individuals opens or closes bank accounts?
4. Which individuals signs checks?
5. Which individuals authorizes payroll?
6. Which individuals makes tax deposits?
7. Which individuals sign tax returns?
8. Which individuals oversee the hiring & termination of employees?
9. Which individuals run business on a day-to-day basis?
The IRS will review these answers based on sufficient documentation.
Additional Actions IRS will Consider
The goal of IRS is to collect the money in full many times taxpayers trying to wiggle away at around this tax and start moving assets around. the IRS knows the tricks and secrets that are used by taxpayers and will do a full investigation to find out if this is the case.
1. Certain facts may surface indicating that transfers of corporate stock and/or capital assets have occurred. If this is the case, in addition to pursuing the TFRP, consider recovery of the unpaid corporate liability by recommending:
• Transferee assessment
• Suit to establish a transferee liability
• Suit to set aside a fraudulent transfer
• Examination referral
It is not hard for the internal revenue for service to find out who responsible parties are. The most damaging one piece of information are the bank signature cards and those persons responsible for making day-to-day decisions. Those are the basic starting point the trust fund recovery penalty.
Call us today for free initial tax consultation and we will walk you through the process of how IRS works to trust one recovery penalties, form 4180, form 2751 and how to get your best achievable result in dealing with the Internal Revenue Service for trust fund penalty issues.
IRS Form 4180 + What You Need to Know + How to Handle the Trust Fund Recovery Interview + Former IRS
