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IRS & Financial ConsultingBrooklyn, NY· Restaurant CFO (W-2 employee, not owner)
Trust Fund Recovery Penalty Defended — Zero Personal Assessment
$186,000
Proposed TFRP
$0
Final personal assessment
Full withdrawal
Outcome
The challenge
A CFO at a multi-location restaurant group was issued Letter 1153 proposing a $186,000 Trust Fund Recovery Penalty for unpaid payroll taxes. He had no signing authority over the operating account.
Our approach
- Pulled bank signature cards and operating-account check stock evidence.
- Documented the owner's exclusive payment-decision authority.
- Prepared the client for IRS Form 4180 interview.
- Filed formal protest with the Office of Appeals after initial assessment.
The outcome
IRS Appeals withdrew the assessment in full after reviewing the responsible-person evidence. Client had zero personal tax liability assessed.
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