Music. The statute of limitations on the Trust Fund Recovery Penalty is that the IRS has to assess the penalty within three years of the April 15th following the calendar year that the payroll taxes were due. So, if it's the first, second, third, and fourth quarters, technically, even though they're overdue, for statute of limitation purposes, April 15th plus three more years is the deadline for assessment by the IRS. In the event that they don't assess it within that three-year period of time, they're barred. Generally speaking, what happens is that the IRS revenue officer conducts an investigation and issues a 60-day letter. If you want to deal with the revenue officer or the appeals officer at a later time, they'll ask you to extend the statute limitations. If you don't extend the statute limitations, they will assess it within that three-year period of time. So, you have to determine whether you want to deal with this revenue officer or appeals officer. If not, don't sign the extension of the statute limitation and they will assess it, leading you through a different process.
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Video instructions and help with filling out and completing Form 843 Statute
