Trust Fund Recovery Penalty Representation

Categories: IRS CE, IRS Resolution
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About Course

This two-hour continuing education course provides tax professionals with a technical, practice-ready understanding of the Trust Fund Recovery Penalty under IRC Section 6672 — the mechanism by which the IRS pursues individuals personally, rather than only the business itself, for unpaid payroll trust fund taxes. This topic does not overlap with any existing course in the current catalog, and the course builds the full framework from the statute itself through assessment procedure, defenses, and collection litigation strategy.

Related Courses

What Will You Learn?

  • Apply IRC Section 6672(a) to identify who may be personally liable for the Trust Fund Recovery Penalty and why the penalty equals the full trust fund amount
  • Identify the specific factors distinguishing a 'responsible person' from an employee with no independent authority over which creditors are paid
  • Apply the 'willfully fails' standard under Section 6672 and distinguish it from criminal intent or fraud
  • Apply IRC Section 6672(d) to determine the right of contribution among multiple responsible persons at the same business
  • Apply IRC Section 6672(b) notice requirements and complete a timely protest of a proposed assessment following Letter 1153 and Form 2751
  • Apply IRC Section 6751(b) supervisory approval requirements to a Trust Fund Recovery Penalty assessment
  • Apply the assessment statute of limitations under Section 6672(b)(3) and Section 6501(b)(3)
  • Explain the divisible-tax procedure for pursuing a refund suit without full payment, and the general nondischargeability of the penalty in bankruptcy

Course Content

Module 1 – The Penalty and the Responsible Person Standard
<p>The Penalty and the Responsible Person Standard</p>

  • The Penalty and the Responsible Person Standard

Module 2 – Willfulness and Multiple Responsible Persons
<p>Willfulness and Multiple Responsible Persons</p>

Module 3 – Assessment Procedure — Notice, Interview, and Appeal Rights
<p>Assessment Procedure — Notice, Interview, and Appeal Rights</p>

Module 4 – Defenses, Collection Litigation, and Practitioner Strategy
<p>Defenses, Collection Litigation, and Practitioner Strategy</p>

Final Assessment – Trust Fund Recovery Penalty Representation
This final assessment consists of 10 multiple-choice questions covering all four modules of this course. A passing score of 70% or better is required.

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