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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,