Successfully reversed an IRS Trust Fund Recovery Penalty assessment against the former President of a Bay Area construction company. The IRS had administratively assessed the Trust Fund Recovery Penalty against our client for payroll taxes owed by his former corporation and of which he was a 1/3 owner. We did not agree with the IRS’ assessment and filed a Claim for Refund with the United States District Court, Northern California. A month before trial the IRS agreed to reverse in full the Trust Fund assessment against our client and refund to him monies seized.
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