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By: Heather L. Marello and Kevin M. Murphy During a recent web conference, IRS Large Business and International Division Commissioner Douglas O’Donnell warned that IRS is gearing up to initiate hundreds of non-filer audits against high income individuals and those with related flow-through entities. The original announcement of this initiative came in July, 2019, when LB&I added high income non-filers
By: Kevin Murphy, Esq. In our most recent blog post, we discussed the importance of timely payment of payroll taxes and how serious the IRS is taking the issue of criminalizing the Trust Fund Recovery Penalty. As a follow up, we wanted to pass along a recent news release from the IRS that highlights the conclusion of an unprecedented two
By: Kevin Murphy, Esq. In Part 1, of this blog, we explained and discussed the civil aspects of IRC 6672- the Trust Fund Recovery Penalty (TFRP). At the end of Part 1, we mentioned that the civil statute is virtually identical to the criminal statute. The two statutes are highlighted below: Section – IRC 6672 (Civil) Any person required to collect,
By: Kevin Murphy, Esq. PART ONE When we discuss potential liability for the Trust Fund Recovery Penalty (TFRP)- I.R.C. § 6672, we often find the need to explain how payroll taxes work. Many clients, some lawyers and accountants and unfortunately even some IRS agents and Assistant U. S. Attorneys don’t really understand what constitutes a trust fund liability. Everyone has
WHEN: October 5-7, 2017 WHERE: Las Vegas, NV Kevin Murphy Presenting Topic: Officers, Officers, Officers Dealing with Tax Compliance Officers (Office Auditors), responding to Revenue Officers, handling Appeals Officers, and negotiating with Settlement Officers, it’s what we do. Day in, and day out. Building on 20+ years of experience on the dark side, Kevin will offer insights, tips, and techniques for dealing with the various IRS