We are an Affordable Professional full service IRS tax firm that specialize in the resolution of all IRS tax matters. We are specialists for those who owe IRS back payroll taxes, 941 tax debt.
Being a former IRS revenue officer and teaching instructor, I worked hundreds upon hundreds of payroll tax cases and I understand the complexities and have immediate resolution options to go over to resolve any IRS tax debt problem. IRS is usually generally aggressive on back payroll tax issues. I would advise all taxpayers to be current in the present quarter. IRS tends to work with businesses and taxpayers that are rehabilitative and are attempting to stay current.
Hiring a professional tax firm can keep IRS out of your business so you can continue to manage and make your business profitable.
Each and every case has a viable solution. The key is knowing every possible option.
If you do not understand the IRS methods, IRS can dictate the way they choose to work your case. the fear of dealing with Internal Revenue Service and the threats that they can make can force taxpayers into decisions that is not in their best interest.
Unless you know the way the Internal Revenue Service operates you have no idea what you’re truly settling for.
As a former IRS agent revenue officer I can tell you that most taxpayers have no clue what’s going on in as a general rule they will believe anything the agent is telling them.
Don’t be trapped or tricked in to this mentality. It is well worth hiring a professional tax firm to deal with your back IRS tax debt payroll problem.
Due to our years of experience with the IRS, we know exactly how to handle IRS and find success in dealing with those who all back payroll tax debt to the Internal Revenue Service.
When you work with us we will submit an immediate power of attorney so the Internal Revenue Service only deals with us and you will never have to speak to IRS.
We will secure and review the necessary financial statements, the 433A& 433B, and talk to you about working out a viable solution to protect your business from the Internal Revenue Service.
Taxpayer should beware that IRS will impose a 6672 penalty, or the trust fund penalty for those responsible persons who were authorized to pay the back payroll taxes.
6672
a) General rule
Any person required to collect, truthfully account for, and pay over any tax imposed by this title who willfully fails to collect such tax, or truthfully account for and pay over such tax, or willfully attempts in any manner to evade or defeat any such tax or the payment thereof, shall, in addition to other penalties provided by law, be liable to a penalty equal to the total amount of the tax evaded, or not collected, or not accounted for and paid over.
No penalty shall be imposed under section 6653 or part II of subchapter A of chapter 68 for any offense to which this section is applicable.
(b) Preliminary notice requirement
(1) In general
No penalty shall be imposed under subsection (a) unless the Secretary notifies the taxpayer in writing by mail to an address as determined under section 6212 (b) or in person that the taxpayer shall be subject to an assessment of such penalty.
(2) Timing of notice
The mailing of the notice described in paragraph (1) (or, in the case of such a notice delivered in person, such delivery) shall precede any notice and demand of any penalty under subsection (a) by at least 60 days.
(3) Statute of limitations
If a notice described in paragraph (1) with respect to any penalty is mailed or delivered in person before the expiration of the period provided by section 6501 for the assessment of such penalty (determined without regard to this paragraph), the period provided by such section for the assessment of such penalty shall not expire before the later of—
(A) the date 90 days after the date on which such notice was mailed or delivered in person, or
(B) if there is a timely protest of the proposed assessment, the date 30 days after the Secretary makes a final administrative determination with respect to such protest.
(4) Exception for jeopardy
This subsection shall not apply if the Secretary finds that the collection of the penalty is in jeopardy.
Definition of wilfulness
1. The trust fund recovery penalty is a civil penalty; so the degree of wilfulness in failing to collect or pay over any tax leading to liability for this penalty is not as great as that necessary for criminal proceedings.
wilfulness in the context of the TFRP is defined as intentional, deliberate, voluntary, and knowing, as distinguished from accidental. “wilfulness” is the attitude of a responsible person who with free will or choice either intentionally disregards the law or is plainly indifferent to its requirements. Some factors to consider when determining wilfulness are:
• Whether the responsible person had knowledge of a pattern of noncompliance at the time the delinquencies were accruing;
• Whether the responsible person had received prior IRS notices indicating that employment tax returns have not been filed, or are inaccurate, or that employment taxes have not been paid;
• The actions the responsible party has taken to ensure its Federal employment tax obligations have been met after becoming aware of the tax delinquencies; and
• Whether fraud or deception was used to conceal the nonpayment of tax from detection by the responsible person.
Call us today for a free initial tax consultation and hear the truth. we will go over with you every option to go ahead and settle your tax debt with the Internal Revenue Service.
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