In this article tax attorney Robert E. McKenzie discusses the Trust Fund Recovery Penalty.
The Internal Revenue Service Restructuring and Reform Act of 1998 requires the Secretary to grant an installment agreement, at the taxpayer’s option, if:
• the liability is $10,000, or less (excluding penalties and interest);
• within the previous 5 years, the taxpayer has not failed to file or to pay, nor entered an installment agreement under this provision; [Act § 3467; IRC § 6159)
Robert E. McKenzie ©2012 Custom Search The IRS recently relaxed its rules for payment of…