Being a former revenue officer I can tell you there are generally two types of ways that revenue officers work “Trust Fund” cases.

At IRS you have a mixed bag of tricks of Revenue Officers who work for on cases.

I have pretty much categorize them into two different areas.

First, those who do their due diligence and come up with the correct assertion of  who is truly responsible for the trust fund penalty,

Second, those who generally just throw a cast net and drag everyone in that they possibly can.

Looking at those who do their due diligence, these revenue officers look at the 4180s, look at the corporate resolutions, look at bank signature cards, look at who signed tax returns and try to narrow  down the field to find out who was truly responsible for the trust fund tax.

They make sure those who are on the fringes do not have to go through the appellate process or possibly the assessment process of having to pay the trust fund tax liabilities.

The second area of those who just throw a cast net around every body. They review who signed bank signature cards, who signed tax returns, those who knew anything about the business and they will set up everyone who they possible can and try to shake down everyone and let the appeals division sorted it all out.

These are generally what I call the lazier revenue officers who shrug their responsibility.

They do not do their proper due diligence and do not take a true look at the situation and realize how much damage and money it cost for people to make a tax defense against the trust fund.

Tax Tip :If you run into type II those who throw a cast net around everyone, make sure you speak to the group manager and state your case to help alleviate the trust fund penalties around your clients addiction situation exist.