Trust Fund Recovery Penalty

From the Government’s perspective, statutes of limitation restrict the taxpayer’s right to claim a refund of
overpaid tax or initiate litigation to obtain a refund. From the taxpayer’s perspective, statutes of limitation
prevent the IRS from collecting a deficiency in tax or beginning a civil or criminal case. In short, statutes of
limitation provide a date of finality after which actions taken by the IRS or the taxpayer cannot be disturbed by

the other party