Can Form 843 Liability 2011-2023

So if we talk about strategy what do we what do we do if we're faced with it what can we do for the client well first of all on collectability collectability could in itself be a defense so we talked about collectability if your client is unable to pay due to a financial hardship so this is talking about the individual that might be assessed that trust fund recovery penalty the IRS can choose not to apply it it's not required by the way than an individual supply personal financial information as they're being investigated but if they don't have the ability to pay if they're assessed you might want to go ahead and give them a voluntary 433 a form and request that they don't assert it based on their financial condition however keep in mind they still might especially in cases where a business is a repeat offender or they continue to pyramid the tax so if you don't have one of those cases sometimes that can be you know on collectability a defense because they don't want to assign it one of the statistics they found is that a great portion that I remember what that is but a very very large majority of all these trust fund recovery penalty taxes this really the person doesn't have the ability to pay or they don't ever collect it so it is at least a valid defense look at check signing authority during the investigation process the IRS will subpoena the bank for records and check signature cards they can shoot it consider check signers to be in control of company finances so a decision-maker in other words however sometimes a check signer doesn't have control of the finances so my example before like an accounting clerk there...