Tag: Trust Fund Recovery


Recent Tax Court rulings may allow refunds of previously assessed penalties

By: Derek B. Wheeler, Esq. and Heather L. Marello, Esq. As part of the Restructuring and Reform Act of 1998 (“RRA 98”), Congress enacted IRC §6751(b)(1), which requires written supervisory approval for certain penalties proposed by the IRS.  Much of RRA 98 focused on legislative controls to prevent abusive practices by IRS personnel which had come to light in the

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