Trust Fund Recovery Penalty (TFRP): What It Is, Who the IRS Targets, and How to Fight Back

You open the letter from the IRS, and your stomach drops. You owe how much?

Maybe business has been tight. Cash flow stretched thin. You made payroll, so your employees got paid, but the tax deposits fell behind. You told yourself you'd catch up next quarter when that big contract came through. You thought the IRS would come after the business, not you personally. After all, isn't that why you set up an LLC?

But now, you're holding a notice with your name on it. Not your company's name—yours. The IRS is saying you're personally responsible for tens of thousands, maybe hundreds of thousands of dollars in unpaid payroll taxes. They're talking about your house, your bank accounts, and your personal assets.

This is the Trust Fund Recovery Penalty, and it's one of the IRS's most aggressive enforcement tools.

If you're facing a Trust Fund Recovery Penalty, or even if you're worried your business might be headed in that direction, you need to understand what you're dealing with. The TFRP allows the IRS to “pierce the corporate veil,” meaning you are held personally liable for the full amount of unpaid trust fund taxes. That's 100% of the taxes withheld from employee paychecks but not paid to the government.

Essentially, it means the government can come after your personal assets, completely bypassing any limited liability protections of your LLC or corporation.

Tax problems are nothing to shrug off, but they’re not insurmountable either. You simply have to get in front of the issue as soon as possible and contact a reliable tax attorney to help you plan a way forward.

At Gabaie & Associates, LLC, we help businesses and individuals get a hold of their tricky tax situations and deal with the IRS on their behalf. Call us today for a free consultation at 410.358.1500.

What Is the Trust Fund Recovery Penalty?

The TFRP exists to ensure that business owners and financial managers cannot use

employees' tax withholdings to cover other business expenses. When a business withholds payroll taxes—such as federal income tax, Social Security, and Medicare—from employees' paychecks, it holds that money in trust for the U.S. Treasury. These funds don’t belong to the business; they belong to the employees and the federal government.

When those trust fund taxes are not remitted to the IRS, it can assess a penalty under the Internal Revenue Code (IRC §6672). This penalty equals 100% of the unpaid trust fund taxes, which is why it's often called the "100% penalty." The IRS can pursue this penalty from any individual deemed a "responsible person" in the business who willfully failed to pay over the taxes.

Image placeholder: Diagram showing trust fund tax flow from employee paycheck  business withholding  IRS, with a red X showing where the breakdown occurs

Why the IRS Uses the TFRP 

The TFRP serves several purposes for the IRS:

• Deterrence: The penalty deters business owners from using employees' withheld taxes to pay other creditors or operating expenses. The threat of personal liability creates a powerful incentive to prioritize payroll tax obligations.
• Protecting Employee Funds: Employee-withheld funds are never the company's money to use, as they belong to the employees and the government from the moment they’re withheld. The TFRP ensures these funds reach their intended destination.
• Piercing the Corporate Veil: The TFRP allows the IRS to bypass limited liability protections. Even if your business is structured as an LLC or corporation, the government can come after the personal assets of responsible individuals. It puts your home, vehicles, bank accounts, and other personal property at risk.

What the TFRP Is Not 

It also helps to understand what the TFRP is not:

• Not a Criminal Charge: The TFRP itself is a civil penalty, not a criminal charge. However, extreme cases of payroll tax evasion can trigger separate criminal prosecution under IRC §7202.
• Not a One-Time Penalty: The TFRP can be assessed for multiple tax quarters. If your business continues to fall behind on payroll taxes across several quarters, you could face separate TFRP assessments for each quarter, compounding your personal liability.
• Not Dischargeable in Bankruptcy: Unlike many debts, you cannot discharge a TFRP through bankruptcy. Trust fund tax debts are classified as priority debts that survive bankruptcy proceedings.

What Are Trust Fund Taxes?

Before we go further, let’s be clear about what trust fund taxes are exactly.

What IS Included in Trust Fund Taxes

• Federal income tax withholding from employee paychecks
• Employee portion of Social Security tax (6.2% of wages)
• Employee portion of Medicare tax (1.45% of wages)

What Is NOT Included

• Employer portion of Social Security and Medicare taxes (these are the employer’s own tax obligations, not funds held in trust)
• Penalties and interest on late payroll tax deposits
• Federal Unemployment Tax (FUTA)

Many business owners believe they can use withheld payroll taxes temporarily to cover cash flow problems, intending to "catch up" once business improves. This misconception is dangerous, however.

Even temporary use of trust fund taxes triggers TFRP exposure. The IRS doesn't care if you intended to pay the taxes eventually. Choosing to pay vendors, rent, or other expenses while trust fund taxes remain unpaid is considered willful failure.

Who Can Be Held Personally Liable for the TFRP?

One of the most frightening aspects of the TFRP is how broadly the IRS defines a "responsible person." It's not just the company's owner or CEO who might be on the hook. Anyone with a duty and power to direct the use of trust fund taxes can be assessed this penalty.

The IRS Definition of a “Responsible Person”

The IRS looks at two key factors when determining who to assess for the TFRP:

1. Duty: Did you have a duty or obligation to ensure payroll taxes were paid?
2. Authority: Did you have the power or authority to direct which bills got paid?

If you had both duty and authority—even if you didn't exercise them—you can be deemed a responsible person. Job titles don't matter as much as duties. The IRS looks at who actually controlled the finances and had the ability to ensure the IRS got paid.

The IRS must follow the guidelines in Internal Revenue Manual (IRM) 5.7.3.4.1 to establish responsibility for TFRP assessment.

Common Targets of TFRP Assessments

The IRS frequently assesses the TFRP against:

• Business owners and founders
• Corporate officers (CEO, CFO, Treasurer, Secretary, President)
• LLC members and managing partners
• Payroll managers and financial controllers
• Bookkeepers and accountants with check-signing authority
• Third-party payroll service providers
• Family members listed as officers "on paper only" (even if they weren't actively involved)

Even a receptionist or clerical worker who simply followed orders to pay other bills before taxes could unexpectedly find themselves targeted if they had actual authority or knowledge regarding tax payments. The IRS casts a wide net.

Multiple Responsible Persons

More than one person in a company can be assessed the full TFRP. The IRS often targets multiple responsible individuals for the same unpaid tax debt under a doctrine called "joint and several liability."

Here’s how joint liability works:

• The IRS can pursue each responsible person for the full amount.
• The government won't collect more than the total tax due, but they can go after anyone assessed until the debt is paid.
• If one responsible person pays the full penalty, the others are released—but the IRS will pursue whoever they think they can collect from most easily.

This joint liability makes it crucial for each potentially responsible person to mount a strong defense, even if someone else in the company was primarily at fault.

How the IRS Defines “Willful”

If you’re found responsible for a payroll tax violation, that’s not proof enough for the IRS to assess the penalty. IRM 5.7.3.4.2 requires the agency also to show that you willfully committed the violation.

IRS Standard for Willfulness

Willfulness in this context doesn't necessarily mean evil intent, bad faith, or fraud. The IRS defines willfulness as:

• Conscious, voluntary, and knowing failure to pay
• Knowledge or reckless disregard of the unpaid taxes
• Paying other creditors while knowing the IRS wasn't being paid (based on Roth v. United States, 779 F.2d 1567 (11th Cir. 1986)).

You don’t have to personally benefit from the money or orchestrate an elaborate scheme for behavior to be willful. Simply paying other bills (rent, suppliers, net wages) while the IRS goes unpaid is enough, if you knew about the tax debt.

Examples of Willful Conduct According to the IRS

The IRS typically finds willfulness when you’re:

• Continuing business operations and paying expenses while payroll taxes go unpaid
• Signing checks to vendors, suppliers, or landlords while knowing taxes are delinquent
• Paying net wages to employees without ensuring taxes are deposited
• Delegating payroll responsibilities without proper oversight or verification
• Recklessly disregarding obvious warning signs (IRS notices, missing deposits)

The burden of proving willfulness is technically on the IRS, but in practice, the threshold isn't very high. The agency often infers willfulness from the circumstances. For example, continued business operations during quarters when taxes weren't paid is a red flag.

Common Situations That Aren’t Automatically Willful

If you want to argue that you weren’t willful, you must show that you truly had no knowledge of the unpaid taxes or no ability to influence the payments.

Examples include:

• Lack of Actual Authority: You were an officer in title but completely uninvolved in financial affairs, with no access to bank accounts or financial decision-making.
• Being Misled by Partners: A rogue bookkeeper or business partner hid the delinquency from you, and you had no reason to suspect otherwise. You were actively deceived.
• After-the-Fact Involvement: You joined the company or assumed the responsible position after the tax debt had already accrued. The IRS can only penalize you for periods when you had the duty to ensure taxes were paid.

Building this defense against your willfulness requires a great deal of evidence and research. A tax attorney can help you by gathering all this information for you, which can often be time-consuming.

How the IRS Investigates TFRP Cases

Image placeholder: TFRP investigation timeline, showing the following steps:

1. Missed payroll deposits
2. FTD notices issued
3. Revenue Officer assigned
4. Form 4180 interview
5. Letter 1153 issued
6. Appeal window (60 days)
7. Assessment → CP15

The road to a TFRP assessment typically begins with a business falling behind on payroll tax deposits. The IRS is aggressive and serious about collecting payroll taxes. Even a shortfall will trigger warning signs. Here's how a payroll tax issue escalates:

1. FTD Notice & Assignment of a Revenue Officer

Federal Tax Deposit (FTD) Notices: If your business misses a payroll tax deposit or filing, the IRS will usually send an initial notice or warning (often an FTD Alert) to the business. This alert means that the IRS knows you're behind.

Assignment of a Revenue Officer: When payroll taxes remain delinquent, the case is referred to a local IRS Revenue Officer (RO) for a full investigation and collection action. The Revenue Officer's job is to get the business back into compliance and determine who was responsible. At this stage, the RO might send a Form 930 to the business, which instructs the company to set up a special trust account for tax deposits. At this point, the IRS is getting very serious.

2. IRS Interviews & Form 4180

If taxes still aren't paid, the Revenue Officer will start identifying potential responsible individuals. The RO will typically schedule an interview (via a Letter 3586 or similar notice) with those involved in the business's finances.

Form 4180 is dangerous without counsel. In this interview, the officer uses IRS Form 4180 (Report of Interview) to ask detailed questions about who had control over finances and decision-making. This interview is critical, and anything you say is under penalty of perjury. The IRS will use your answers on Form 4180 to decide if you individually should be assessed the TFRP.

It's not actually required to sign Form 4180 on the spot, and you should be very careful in this interview. Having a tax attorney present or coaching you beforehand can prevent damaging admissions. For example, you may not want to concede you "paid other bills instead of the IRS" without context, as that could seal the case against you.

Throughout the investigation, the Revenue Officer will scrutinize:

• Bank records and signature cards (who had authority to sign checks)
• Corporate documents (articles of incorporation, bylaws, operating agreements)
• Payroll tax filings (Forms 941, 944) and deposit records
• Internal emails and accounting records showing who made financial decisions
• Check registers showing what bills were paid and when

Early representation changes outcomes. Many business owners have inadvertently hurt their case by trying to "explain things" to a Revenue Officer informally, only to make statements that later became evidence of responsibility or willfulness. Once you're in the IRS's crosshairs for payroll taxes, you're better off with legal counsel guiding the interaction.

We also know the common IRS investigative shortcuts that can be challenged. For example, Revenue Officers sometimes assume that anyone with check-signing authority is automatically responsible, or they rely too heavily on corporate filings without investigating actual day-to-day operations. An experienced tax attorney can push back on these assumptions and present evidence that tells the full story.

IRS Letter 1153 & Form 2751 Explained

After the Revenue Officer's investigation, if they believe you are a responsible, willful party, the IRS will issue IRS Letter 1153 to you. This moment is critical in the TFRP process.

What Is IRS Letter 1153?

Letter 1153 is the formal notice that the IRS intends to assess a Trust Fund Recovery Penalty against you personally. This notice is important because it’s:

• A proposed assessment notice (not yet final)
• Your last administrative chance to dispute the TFRP before it becomes official
• Accompanied by Form 2751 (explained below)

By the time you receive Letter 1153, the IRS has already built a preliminary case that you are responsible and willful in not paying the payroll taxes. However, it’s not yet a final determination, and you still have the right to challenge it.

What Is Form 2751?

Form 2751 is essentially an agreement form. If you agree with the proposed penalty, you can sign Form 2751 to consent to the assessment.

Consequences of signing: By signing Form 2751, you're saying you accept the liability. After which, the IRS will assess the penalty and eventually demand payment in full (with interest) or set up a payment plan for you as an individual. Signing waives your right to contest the penalty through an appeal.

Do NOT sign Form 2751 without consulting a tax attorney. Unless you're absolutely certain there's no defense and perhaps have a deal in place, it's wise to at least explore your appeal options before signing away your rights.

Critical Deadlines

You have 60 days from the date of Letter 1153 to appeal (75 days if the letter was addressed to you overseas). Failing to respond within that window means you lose the right to contest the penalty through the IRS appeals process.

What happens if you miss the deadline: If you do nothing, after 60 days the assessment becomes final. The IRS will assess the penalty against you personally and will eventually send a formal bill (IRS Notice CP15B).

The IRS can then start filing liens or levies on your personal assets to collect the penalty once the assessment is made. That's why the letter warns that "failing to respond may result in penalties or liens" being imposed.

Time is of the essence. The 60-day window is your best opportunity to fight the TFRP through administrative channels.

Your Rights After Receiving Letter 1153

When you receive IRS Letter 1153, you have important rights:

• Right to Appeal: You can request an appeal conference with the IRS Office of Appeals within 60 days.
• Right to Representation: You have the right to have a tax attorney represent you throughout the process. Your attorney can handle all communications with the IRS on your behalf.
• Right to Challenge Responsibility and Willfulness: You can present evidence that you were not a responsible person or that you did not act willfully.
• Right to Negotiate Before Assessment: The appeals process allows for settlement negotiations based on "hazards of litigation"—essentially, if the IRS sees some risk it might lose in court, it can compromise.

These rights are valuable, but they expire if you don't act within the 60-day deadline.

The TFRP Appeals Process (Step-by-Step)

Image placeholder: flowchart illustrating the TFRP appeals process:

IRS Letter 1153 Issued

→ 60-Day Response Window

→ Appeal Filed?

• Yes → IRS Appeals Review → Appeals Conference → Penalty Withdrawn / Reduced / Sustained
• No → TFRP Assessed → CP15 Issued → IRS Collection Actions

If you request a TFRP appeal on time, you gain important rights and some breathing room. Here's what to expect:

Filing a Formal Protest

To initiate an appeal, you (or your attorney) must send a formal written protest letter to the IRS within 60 days of Letter 1153. The protest should include:

• Your name, address, and contact information
• A statement that you want to appeal the proposed TFRP to the Office of Appeals
• The tax periods and amounts at issue
• A description of the disputed issues and your position on each issue
• Legal and factual arguments supporting your position
• Supporting documents or evidence

For smaller TFRP amounts (under certain thresholds), an informal protest may apply, but a comprehensive formal protest is generally advisable to present your strongest case.

Appeals Conference

After you submit your protest, the IRS should send you a Letter 4141 acknowledging your appeal and informing you that an Appeals Officer has been assigned. Soon after, you'll receive another letter scheduling a conference (usually by phone, or sometimes in person) with the Appeals Officer.

What happens: The conference is essentially a negotiation and fact discussion. The Appeals Officer will review your case, the Revenue Officer's findings, and your protest arguments.

Role of your attorney: You have the right to bring an authorized representative (your tax attorney) to handle the discussion for you. They can do all the speaking on your behalf and consult with you during the conference.

Evidence that matters most:

• Corporate documents showing limited authority or role
• Testimony or affidavits from colleagues about actual responsibilities
• Evidence you were misled or kept in the dark about the tax debt
• Documentation showing you joined after the debt accrued or left before it occurred
• Financial records demonstrating another person had greater control

Possible Outcomes

After the conference and reviewing evidence, the Appeals Officer will issue one of the following decisions:

• Full Withdrawal: The Appeals Officer concludes you shouldn't be liable and abates the penalty entirely.
• Partial Assessment: Appeals might drop the penalty for certain quarters, remove one individual from liability, or reduce the amount based on evidence.
• Hazards-of-Litigation Settlement: If the Appeals Officer sees some risk that the IRS might lose if you went to court, they can compromise and accept a percentage of the total penalty to settle the case.
• Full Assessment: The Appeals Officer sustains the proposed TFRP in full.

Many TFRP cases are partially settled. If an agreement is reached, you'll typically need to sign an appeals agreement form and then arrange to pay whatever amount was agreed upon (or set up a payment plan).

If you don't settle: If no agreement is reached, the case returns to IRS Collections for immediate assessment of the full penalty, and you'll soon receive a bill. At that point, your only remaining recourse to contest liability is paying a portion of the penalty and suing for a refund.

Statute of Limitations for TFRP

Two separate time limits apply in TFRP cases:

1. Assessment Statute (3 years)

The IRS generally has 3 years from the filing of a tax return to assess a TFRP for that period. More specifically, the clock starts running on either the date the employment tax return (Form 941 or 944) was filed, or the April 15 deadline for filing that return, whichever is later.

If a return is filed late, the 3-year period begins from the actual filing date.

Extensions and tolling events: Certain events can extend or suspend the statute, including bankruptcy proceedings, pending Offer in Compromise applications, or when the taxpayer is outside the United States for extended periods.

If the IRS waited too long or made a procedural misstep in assessing the TFRP, you could potentially mount a statute of limitations defense.

2. Collection Statute (10 years)

Once the TFRP is assessed, the IRS has 10 years to collect on the debt. This collection statute begins on the date of assessment.

Certain actions pause the 10-year clock, including:

• Filing for bankruptcy (suspends collection statute for duration of bankruptcy plus 6 months)
• Submitting an Offer in Compromise (suspends during review plus 30 days)
• Requesting a Collection Due Process hearing
• Military service in a combat zone

That means a TFRP can hang over you for a decade if not resolved.

The 3-year statute limits when the IRS can assess a Trust Fund Recovery Penalty.

The 10-year statute limits how long the IRS can collect once the penalty is assessed.

What Happens After the TFRP Is Assessed?

If the TFRP is assessed (either because you didn't appeal in time or your appeal was unsuccessful), the IRS will send you a Notice CP15 or CP15B. This is essentially a Notice and Demand for Payment showing the amount you owe personally.

Do not ignore a CP15 notice. Once the TFRP is assessed, it becomes legally equivalent to a personal tax debt, and the IRS has powerful collection tools at its disposal:

• Tax Liens: The IRS can file a federal tax lien in your name, which attaches to any property you own (home, vehicles, etc.) and appears on your credit report, devastating your credit score.
• Levies: The IRS can levy (seize) your bank accounts, investment accounts, and other assets.
• Wage Garnishment: The IRS can garnish your personal wages or salary to collect the debt.
• Seizure of Personal Assets: In extreme cases, the IRS can seize and sell your personal property to satisfy the debt.

Interest on a TFRP balance starts accruing 21 days after the first bill if not paid. That interest compounds daily. The longer you wait to resolve it, the larger the balance grows.

Resolving a Trust Fund Recovery Penalty

Even after a TFRP is assessed, you still have options for resolving the debt:

• Installment Agreements: If you can't pay in full, you can contact the IRS to set up an installment agreement to pay over time. The IRS may ask for financial information to size a monthly payment. Remember that interest continues to accrue on any unpaid balance.
• Offer in Compromise: If you agree you owe the penalty but simply can't pay in full, you might pursue an Offer in Compromise (tax settlement) based on doubt as to collectability, to settle the debt for less than the full amount.
• Partial Payment Strategies: If you strongly believe the TFRP was wrongfully assessed, you can pay a portion of the penalty (typically the trust fund penalty for one employee for one quarter) and file a claim for refund, then potentially sue for a refund in federal court.
• Abatement Through Corporate Payment: Sometimes a business will pay the underlying payroll tax debt, which may result in abatement of the TFRP. This is an internal business decision, but it's worth exploring.

Filing for bankruptcy could stop TFRP collection actions like levies, but you cannot discharge a TFRP in bankruptcy. According to IRM 8.25.1.6, trust fund tax debts are classified as priority debts that survive both Chapter 7 and Chapter 13 bankruptcy proceedings.

Even at the CP15 stage, a skilled tax attorney can negotiate with the IRS to resolve the debt without litigation.

Common Defenses to a TFRP Assessment

Facing a proposed Trust Fund Recovery Penalty can feel overwhelming, but there are defenses and strategies that can be effective:

• Lack of Responsibility: A common defense is showing that you did not have significant control over finances or decision-making authority for tax matters. Documentation like corporate bylaws, job descriptions, testimony from colleagues, or proof that you lacked access to bank accounts can support this. The IRS can only penalize someone for periods during which they had the duty to ensure taxes were paid.
• Lack of Willfulness: Perhaps you technically were a responsible person, but you did not act willfully. Evidence that you were misled, kept in the dark, or that you never consciously chose to prefer other creditors over the IRS can negate willfulness.
• Statute of Limitations Expired: If the IRS waited too long to assess the TFRP (beyond the 3-year assessment period), the penalty can be invalidated.
• IRS Procedural Errors: Sometimes, the Revenue Officer can make mistakes in the investigation or assessment process. Challenging procedural errors can weaken the IRS's case.
• Collectability Arguments: Even if liability is established, demonstrating financial hardship or inability to pay can lead to reduced settlement offers or manageable payment plans.

Image placeholder: visual chart with icons for each type of defense above

Never underestimate the value of professional guidance. The IRS Appeals Officers and lawyers know which firms are willing and able to fight. We leverage our credibility and knowledge of IRS protocols to negotiate settlements when appropriate and litigate when necessary.

Why TFRP Cases Require an Experienced Tax Attorney

Dealing with the Trust Fund Recovery Penalty is not a battle you want to face alone. The IRS agents and attorneys pursuing these penalties are focused on one thing: collecting the government's money, often from your personal assets.

Attorney-Client Privilege: By working with Gabaie & Associates, LLC on your TFRP case, you won't have to face the United States Government alone. With legal representation, you’ll have attorney-client privilege, meaning you can speak candidly about your situation with your attorney, without fear that your statements will be used against you. This protection doesn't exist when speaking directly to the IRS.

IRS Procedural Knowledge: Tax attorneys understand IRS procedures, deadlines, and requirements. We know how to navigate the system to protect your rights and maximize your chances of a favorable outcome.

Strategic Handling of Interviews: The Form 4180 interview with a Revenue Officer is dangerous without counsel. An attorney can prepare you for the interview, attend with you, or even handle communications on your behalf to prevent damaging admissions.

Appeals and Litigation Readiness: Our firm has extensive experience preparing comprehensive, persuasive appeal letters and protest packets that win at the IRS Appeals level. If necessary, we're prepared to litigate in federal court.

Why Choose Gabaie & Associates, LLC

Tax Law Focus: Our attorneys have legal and accounting backgrounds, bringing a comprehensive understanding of tax issues. We’ve saved our clients millions of dollars and secured full abatement of penalties in the amount of over $3 million.

IRS Controversy and Appeals Experience: We have extensive experience with IRS Revenue Officers, Appeals Officers, and the entire TFRP process. We know what works.

Personalized, Proactive Representation: We combine an urgent, proactive approach with a reassuring demeanor. We understand that each client's business needs are unique, and we provide personal attention to protect your interests.

Frequently Asked Questions About the Trust Fund Recovery Penalty

Can the IRS assess more than one person for the same TFRP?

Yes. The IRS often assesses multiple responsible individuals for the same unpaid tax debt under joint and several liability. The government won't collect more than the total tax due, but it can pursue all assessed parties until the debt is paid.

Can I go to jail for the TFRP?

The TFRP itself is a civil penalty, not a criminal charge. However, extreme cases of payroll tax evasion can trigger separate criminal prosecution under the IRC §7202. Willful failure to pay over trust fund taxes is a felony. The IRS typically reserves criminal prosecutions for egregious cases or blatant tax evasion.

Can the TFRP be removed or abated?

Yes, in one of several ways:

1. Successfully appealing the proposed assessment by proving you weren't responsible or willful
2. Challenging an assessed TFRP through a refund lawsuit
3. Having the underlying business pay the payroll tax debt, which may result in TFRP abatement
4. Demonstrating the statute of limitations expired before assessment.

What if my business is closed? Am I still liable?

Yes. The TFRP creates personal liability that survives the closure or dissolution of the business. Even if the company is no longer operating, the IRS can pursue you individually for the penalty.

Does signing checks automatically make me liable for TFRP?

Not automatically, but it's a strong indicator of responsibility. The IRS looks at the totality of circumstances, including who had check-signing authority, who made financial decisions, who had access to bank accounts, and who had the duty to ensure taxes were paid. Signing checks is one factor, but not the only one.

Can the TFRP be discharged in bankruptcy?

No. Trust fund tax debts are classified as priority debts that cannot be discharged in either Chapter 7 or Chapter 13 bankruptcy. This fact gives the IRS significant leverage in collection efforts.

Don't Wait—The IRS Won't

Time is of the essence when it comes to the IRS. If you've received a TFRP notice or have payroll tax troubles, the worst thing you can do is nothing. The IRS isn’t going away, and the longer you wait, the fewer tools remain.

In addition, the sooner you seek professional help, the more options you'll have to protect yourself and your assets. With knowledgeable legal counsel like the team at Gabaie & Associates, LLC, you have defenses to present, options to negotiate, and strategies

to minimize the damage.

We encourage you to get in touch as soon as you suspect a payroll tax problem. Early intervention makes all the difference. We may be able to prevent a TFRP from ever being assessed or mitigate the consequences if one has already been proposed.

Contact us today for a free, confidential consultation. Call 410.358.1500 or send your information via our contact form, and we’ll be in touch with you.

Don't let the IRS take your personal assets. Reach out to the reliable tax attorneys at Gabaie & Associates, LLC, and start protecting yourself today. With the right strategy, you won't have to face the IRS alone.