Howard Levy is a Cincinnati tax attorney with the experience to find solutions to your IRS problems.

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How to stop an IRS trust fund recovery penalty interview

By Howard S. Levy, Esq., Employment taxes, Revenue Officers, Statute of limitations on assessment, Trust fund recovery penalty, Uncollectible

Your business owes the IRS employment taxes, and an IRS Revenue Officer has just called you and requested that you come down to his office for a meeting to discuss the debt. Chances are, the meeting will include the IRS agent requesting to interview you using IRS Form 4180, Report of Interview with Individual Relative to Trust Fund Recovery Penalty. You do not know it, but the real focus of the meeting is you, not the business. That's right, the IRS can collect an unpaid employment tax liability from not just your business, but you, too. The IRS calls this a trust fund recovery penalty ... Read More

IRS Investigations of Unpaid Employment Taxes: A Step-by-Step Guide

By Howard S. Levy, Esq., Employment taxes, Trust fund recovery penalty

It’s an old story that the IRS combats everyday:  When a business struggles and cash flow is tight, when there is not enough money to pay both rent and employment taxes, the IRS takes a back seat, and the business uses employee withholding taxes to keep the lights on. The result is that the IRS is made an unwilling lender to fund operations.   Your hope is that the tide will turn and the IRS can be repaid before they come calling.  Your business is your baby, but this is can be a dangerous bet, and as we will see, it is especially dangerous in employment tax cases. Liability for ... Read More

What to expect from the IRS if your business owes employment taxes: 10 tips

By Howard S. Levy, Esq., Employment taxes, Form 433B, Revenue Officers, Trust fund recovery penalty

Unpaid employment tax liabilities results in the highest level of IRS enforcement.  The IRS usually assigns its most experienced Revenue Officers to investigate employment tax cases, including pursuing the individuals in the business personally for not paying their employees taxes. If your business owes employment taxes to the IRS, what does this mean to you and where does it lead? Let's break it down - 10 tips on what to expect from the IRS, and how to handle the IRS scrutiny. 1.     Yes, the IRS will make an unannounced first visit to your business.  Be respectful and courteous. ... Read More

Why? How? When? Making designated payments to the IRS

By Howard S. Levy, Esq., Automated Collection Service, Employment taxes, IRS Collection Problems, Revenue Officers, Statute of limitations on collections, Trust fund recovery penalty

When you make a payment to the IRS, it will be automatically applied to your account in a manner that is in the IRS's best interest. But what is best for the IRS in handling your payment can be different from what is best for you. In some situations, it is in your best interest to make a designated IRS payment, which tells the IRS how you would like them to handle and apply your payment. Designated payments should be considered in the following situations: 1.     If you owe income taxes, it may be beneficial to designate your payment to pay a more recent tax liability off before ... Read More

Trust fund recovery penalty: The uncollectible defense

By Howard S. Levy, Esq., Currently Not Collectible, Economic hardship and the IRS, Employment taxes, Trust fund recovery penalty

The trust fund recovery penalty can cause financial havoc for anyone involved in a business that did not pay over its employee withholdings to the IRS.  Internal Revenue Code Section 6672 allows the IRS to investigate those in the business who were part of the decision not to pay the IRS and hold them personally responsible for repayment. The amount of the trust fund recovery penalty charged to the individuals is equal to the taxes deducted from employee paychecks but not paid to the IRS. Usually, the trust fund recovery penalty involves defending on the basis of liability - developing ... Read More

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Howard S. Levy

A former IRS trial attorney, Howard Levy has over 20 years of experience representing individuals and companies facing tax controversies.

IRS Practice Areas

  • Automated Collection Service
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  • Bankruptcy and the IRS
    (39)
  • Criminal investigation
    (10)
  • Currently Not Collectible
    (24)
  • Economic hardship and the IRS
    (17)
  • Employment taxes
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  • Innocent spouse
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  • Installment agreements
    (34)
  • Interest and penalties
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  • IRS Audits
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  • IRS collection notices
    (28)
  • IRS Financial Statements
    (37)
  • IRS levies and property seizures
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  • Offer in compromise
    (61)
  • Revenue Officers
    (43)
  • Statute of limitations on collections
    (30)
  • Tax Court
    (17)
  • Tax liens
    (8)
  • Trust fund recovery penalty
    (21)
  • Unfiled returns
    (26)

Learn the Basics

When do I know it’s right to file an offer in compromise? 5 top reasons.

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What to expect when an IRS Revenue Officer comes calling to your home or business.

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Is there such a thing as a hardship status with the IRS?

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Defaulted on your IRS installment agreement? Where do you turn now?

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Will bankruptcy help in getting the IRS to release a levy or seizure?

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