by Jim Magary | Dec 7, 2015 | Tax Help
If you have some issue with payroll trust fund taxes. Call us today and hear the truth about your IRS tax issue, Since 1982. Tax Defense Services Appeals, Negotiation for Tax Debt Settlements 1-866-700-1040
We are true to trust fund recovery penalty tax defense experts.
We have over 65 years of direct working experience in the local, district, and regional tax offices of the IRS.
We are true IRS experts and specialists in trust fund tax and back tax issues. We have over 206 years of professional tax experience in dealing with IRS tax issues and problems.
Being a former IRS agent in teaching instructor I have worked hundreds and hundreds of trust fund recovery penalty cases. We are true experts when it comes to affordable tax defense for any payroll tax issue.
Our firm represents those who need to file appeals or want to settle their tax debt is result of trust fund recovery problems. There are the various type of solutions that after a quick review of your case we can provide different settlement options.
Do not be bullied by the Internal Revenue Service call us today for a free initial tax consultation and hear what true experts have to say about your situation. Being former IRS agents we understand the bullying techniques used by the Internal Revenue Service.
We take no case unless we can provide immediate and permanent tax relief. We’ve been in private practice since 1982 and over 206 years of professional tax experience.
What are Trust Fund Taxes, 6672 penalty, Why will IRS Go After You
If you are one of the individuals responsible to pay the payroll tax debt IRS will look to you to pay the uncollected trust fund taxes. why, read below.
A trust fund tax is money withheld from an employee’s wages (income tax, social security, and Medicare taxes) by an employer and held in trust until paid to the Treasury.
When you pay your employees, you do not pay them all the money they earned. As their employer, you have the added responsibility of withholding taxes from their paychecks.
The income tax and employees’ share of FICA (social security and Medicare) that you withhold from your employees’ paychecks are part of their wages you pay to the Treasury instead of to your employees.
Your employees trust that you pay the withholding to the Treasury by making Federal Tax Deposits (PDF). That is why they are called trust fund taxes.
Through this withholding, your employees pay their contributions toward retirement benefits (social security and Medicare) and the income taxes reported on their tax returns. Your employees’ trust fund taxes, along with your matching share of FICA, are paid to the Treasury through the Federal Tax Deposit System.
The withheld part of these taxes is your employees’ money, and the matching portion is their retirement benefit. For additional information, refer to Employment Taxes and the Trust Fund Recovery Penalty.
Depending on where your cases in the system we will review with you the various options that you have to fully resolve the trust fund recovery penalty.
Even if the IRS is made an assessment against you and we feel that IRS to set you up erroneously, we can file an offer in compromise doubt as to liability.
If you owe the tax we will look at a way to negotiate your tax by putting into to a current hardship, payment agreement or getting IRS to accept an offer in compromise if you are a qualified and suitable candidate for this negotiation.
Call us today for free initial tax consultation and hear the truth about your case and the different settlement and appeals processes.
We can provide you excellent affordable tax defenses the trust fund issues. We are a full service tax firm with expertise in IRS problems especially trust fund penalty assessments.
Trust Fund Penalty, IRS Tax Defense Services + Affordable Former IRS + Since 1982
by Jim Magary | Dec 7, 2015 | Tax Help
Affordable Tax Defense + If you have some issue with payroll trust fund taxes. Call us today and hear the truth about your IRS tax issue, Since 1982.. Appeals, Negotiation for Tax Settlements
We have over 65 years of direct working experience in the local, district, and regional tax offices of the IRS.
We are true IRS experts and specialists in trust fund tax and back tax issues. We have over 206 years of professional tax experience in dealing with IRS tax issues and problems.
Being a former IRS agent in teaching instructor I have worked hundreds and hundreds of trust fund recovery penalty cases. We are true experts when it comes to affordable tax defense for any payroll tax issue.
Our firm represents those who need to file appeals or want to settle their tax debt is result of trust fund recovery problems. There are various type of solutions that after a quick review of your case we can provide different settlement options.
Do not be bullied by the Internal Revenue Service call us today for a free initial tax consultation and hear what true experts have to say about your situation. Being former IRS agents we understand the bullying techniques used by the Internal Revenue Service.
We take no case unless we can provide immediate and permanent tax relief. We’ve been in private practice since 1982 and over 206 years of professional tax experience.
What are Trust Fund Taxes, 6672 penalty
A trust fund tax is money withheld from an employee’s wages (income tax, social security, and Medicare taxes) by an employer and held in trust until paid to the Treasury.
When you pay your employees, you do not pay them all the money they earned. As their employer, you have the added responsibility of withholding taxes from their paychecks.
The income tax and employees’ share of FICA (social security and Medicare) that you withhold from your employees’ paychecks are part of their wages you pay to the Treasury instead of to your employees.
Your employees trust that you pay the withholding to the Treasury by making Federal Tax Deposits (PDF). That is why they are called trust fund taxes.
Through this withholding, your employees pay their contributions toward retirement benefits (social security and Medicare) and the income taxes reported on their tax returns. Your employees’ trust fund taxes, along with your matching share of FICA, are paid to the Treasury through the Federal Tax Deposit System.
The withheld part of these taxes is your employees’ money, and the matching portion is their retirement benefit. For additional information, refer to Employment Taxes and the Trust Fund Recovery Penalty (TFRP).
Depending on where your cases in the system we will review with you the various options that you have resolved the trust fund recovery penalty.
Even if the IRS is made an assessment against you and we feel that IRS to set you up erroneously, we can file an offer in compromise doubt as to liability. If you owe the tax we will look at a way to negotiate your tax by putting into to a current hardship, payment agreement or getting IRS to accept an offer in compromise if you are a qualified and suitable candidate for this negotiation.
Call us today for free initial tax consultation and hear the truth about your case and the different settlement and appeals processes. We can provide you excellent affordable tax defenses the trust fund issues.
Trust Fund Recovery Penalty Problem + IRS Tax Negotiation Settlement + Reduce Tax Bill + Former IRS + IRS 6672 Penalty
by Jim Magary | Dec 7, 2015 | Tax Help
We are a team of former IRS agents, managers and tax instructors. we are to experts in the IRS trust fund recovery penalty.
We are specialist for the representation of those who are undergoing the trust fund recovery investigation, those wishing to file an appeal, for those wishing to settle their tax debt at the trust fund recovery has already been set up.
As a former IRS Revenue Officer, I have worked a large number of Trust Fund Recovery Penalties cases.
The Trust Fund Penalty can and will have a damaging effect on taxpayers who were found to be responsible to pay these taxes.
It was part of my job was to train IRS Agents on determinations for the Trust Fund Recovery Penalty. I have worked more trust fund recovery penalties than I care to admit. I know everything there is to know about this process.
The general rule is, ” hold everyone and anyone responsible” by applying this method, the tax will eventually get paid in full. each agent work their case differently but as a general rule the IRS agent will try to hold everybody responsible for the tax. That’s why there is an appellate process in place that provide solid tax defense mainly because the IRS tries the ramrod these cases through the system.
Though IRS will never admit to this method, the Agent will do just that, they will go after everyone they can for the Trust Fund Recovery Penalty.
When an IRS Agent gets a 941 Payroll or Trust Fund case on their schedule, the very first thing the Agent does, is to make an on-site visit to the corporation, to ask the corporation for full payment.
Many times the corporation is out of business, and the Revenue Officer must track down responsible officers or those who were expected to pay the payroll taxes to the IRS.
Once the IRS has made contact with at least one person who was involved with the company, they will interview the person by taking a detailed and lengthy interview with Form 4180 (Report of Interview with Individual Relative to Trust Fund Penalty)
This 4180 form can be found on our website.
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.
IRS will then contact banks for information such as bank signature cards, corporate resolutions, copies of checks.
One more acid test used by the IRS Revenue Officer, would be to look to see who signed checks and took distributions from the company- the bottom line is, follow the money trail.
When dealing with the Trust Fund Penalty, one should be represented by a professional tax firm or representative.
by Jim Magary | Dec 7, 2015 | Tax Help
Affordable Tax Defense: If you have some issue with payroll trust fund taxes. Call us today and hear the truth about your IRS tax issue, Since 1982.. Appeals, Settlements
We have over 65 years of direct working experience in the local, district, and regional tax offices of the IRS. We are true IRS experts and specialists in trust fund tax and back tax issues.
Being a former IRS agent in teaching instructor I have worked hundreds and hundreds of trust fund recovery penalty cases. We are true experts when it comes to affordable tax defense for any payroll tax issue.
Our firm represents those who need to file appeals or want to settle their tax debt is result of trust fund recovery problems.
Do not be bullied by the Internal Revenue Service call us today for a free initial tax consultation and hear what true experts have to say about your situation.
We take no case unless we can provide immediate and permanent tax relief. We’ve been in private practice since 1982 and over 206 years of professional tax experience.
What are Trust Fund Taxes
A trust fund tax is money withheld from an employee’s wages (income tax, social security, and Medicare taxes) by an employer and held in trust until paid to the Treasury.
When you pay your employees, you do not pay them all the money they earned. As their employer, you have the added responsibility of withholding taxes from their paychecks.
The income tax and employees’ share of FICA (social security and Medicare) that you withhold from your employees’ paychecks are part of their wages you pay to the Treasury instead of to your employees.
Your employees trust that you pay the withholding to the Treasury by making Federal Tax Deposits (PDF). That is why they are called trust fund taxes.
Through this withholding, your employees pay their contributions toward retirement benefits (social security and Medicare) and the income taxes reported on their tax returns. Your employees’ trust fund taxes, along with your matching share of FICA, are paid to the Treasury through the Federal Tax Deposit System.
The withheld part of these taxes is your employees’ money, and the matching portion is their retirement benefit. For additional information, refer to Employment Taxes and the Trust Fund Recovery Penalty (TFRP).
Call us today for free initial tax consultation and hear the truth about your case and the different settlement and appeals processes. We can provide you excellent affordable tax defenses the trust fund issues.
Payroll Trust Fund Taxes Relief + IRS Tax Defense Experts, Former IRS + Trust Fund Specialists
by Jim Magary | Dec 7, 2015 | Tax Help
If you have received IRS letter 1153 DO contact us today to help fight the trust fund tax penalty assessments.
We are true experts for all IRS collection matters including trust fund penalty tax assessments.
We have over 65 years of direct IRS work experience in the local, district, and regional tax offices of the IRS.
We have worked hundreds upon hundreds of these cases both his former IRS agents and in private practice.
You can appeal this tax assessment by reading this blog.
Your receipt of the 1153DO notice starts the trust fund recovery assessment process and it must be followed up.
If IRS sets up this penalty against you collection processes will work as though you all individual taxes. If this assessment is made against you, IRS has the right to send out bank levies, wage garnishment levies and seize any property they feel they have a right to. It is important you answer all IRS correspondence and fight this decision is much as possible.
Taxpayer’s Response to Letter 1153(DO)
1. After Letter 1153(DO) and Form 2751, Proposed Assessment of Trust Fund Recovery Penalty, have been properly delivered, the responsible party has 60 days (75 if the letter was addressed outside of the United States) from the date of the mailing of the notice or the date of personal delivery to respond.
A protest is timely: if it is postmarked or mailed by certified or registered mail, so that the mailing date can be proven, on or before the 60th day (75th day if the letter was addressed outside of the United States) after the date the Letter 1153(DO) was mailed or personally delivered.
A private postage meter stamp is not evidence of when a request for appeal was mailed;it merely establishes when it was stamped.
In determining the timeliness of the appeal, the guidelines in IRC 7503 should be followed which state in part:
When the last day prescribed under authority of the internal revenue laws for performing any act falls on Saturday, Sunday, or a legal holiday, the performance of such act shall be considered timely if it is performed on the next succeeding day which is not a Saturday, Sunday, or a legal holiday.
The Appeal Trust Fund System
Because people sometimes disagree on tax matters, the Service has an appeal system.
Most differences can be settled within this system without going to court.
Reasons for disagreeing must come within the scope of tax laws, however.
For example, an appeal of a case cannot be based only on moral, religious, political, constitutional, conscientious, or similar grounds.
A case may be taken directly to tax court if the taxpayer does not want to appeal within the IRS.
Appeal Within the IRS
The tax decision reached by the examiner may be appealed to a local appeals office, which is separate and independent of the IRS Office that conducted the examination.
An appeals office is the only level of appeal within the IRS. Conferences with appeals office personnel may be conducted in person, through correspondence, or by telephone with the taxpayer or its authorized representative
Instructions for requesting a conference with an appeals officer are provided in the letter of proposed tax adjustment.
In FSLG, the Letter 950 is generally used to propose adjustments to employment taxes. It states that to request a conference with an appeals officer, the taxpayer will need to file either a small case request or a formal written protest with the contact person named in the letter.
Whether you file a small case request or a formal written protest depends on several factors.
If a conference is requested the examiner will send the conference request letter to the appeals office to arrange for a conference at a convenient time and place.
The taxpayer or its qualified representative should be prepared to discuss all disputed issues at the conference.
Most differences are settled at this level.
Making a Small Case Request
A small case request is appropriate if the total amount of tax, penalties, and interest for each tax period involved is $25,000 or less.
If more than one tax period is involved and any tax period exceeds the $25,000 threshold, a formal written protest for all periods involved must be filed.
The total amount includes the proposed increase or decrease in tax and penalties or claimed refund.
To make a small case request, the instructions in the letter of proposed tax adjustment provide that the taxpayer should send a brief written statement requesting an appeals conference and indicate the changes with which it does not agree with and the reasons it does not agree with them.
Be sure to send the protest within the time limit specified in the letter you received, which is generally 30 days.
Filing a Formal Protest
When a formal protest is required, it should be sent within the time limit specified in the letter. The following should be provided in the protest:
• Taxpayer’s name and address, and a daytime telephone number.
• A statement that taxpayer wants to appeal the IRS findings to the Appeals Office.
• A copy of the letter proposed tax adjustment.
• The tax periods or years involved.
• A list of the changes that the taxpayer does not agree with, and reason for disagreement.
• The facts supporting the taxpayer’s position on any issue that it does not agree with.
• The law or authority, if any, on which the taxpayer is relying.
• The taxpayer must sign the written protest, stating that it is true, under the penalties of perjury as follows:
• “Under the penalties of perjury, I declare that I examined the facts stated in this protest, including any accompanying documents, and, to the best of my knowledge and belief, they are true, correct, and complete.”
If the taxpayer’s representative prepares and signs the protest for the taxpayer, he or she must substitute a declaration stating:
• That he or she submitted the protest and accompanying documents and;
• Whether he or she knows personally that the facts stated in the protest and accompanying documents are true and correct.
Call us today for free initial tax consultation and we will walk you through the process of filing an appeal for a trust fund recovery penalty.
