Why the IRS treats this differently
Withheld payroll tax is 'trust fund' money — your employees' and the government's, held in trust by the business. The IRS pursues it far more aggressively than almost any other balance. The TFRP lets the IRS assess the trust-fund portion against individuals — owners, officers, check-signers — anyone it decides was a 'responsible person' who acted 'willfully.' A corporation or LLC normally shields you from business debts; the TFRP punches straight through that shield, which is why a business payroll problem can become a six-figure personal liability that survives the company closing.
What your options actually are
The right path depends on the facts — who controlled the money and what they knew. Options include contesting 'responsible person' status, contesting 'willfulness,' protesting the proposed assessment within Letter 1153's deadline, resolving the business liability, and addressing personal exposure once assessed. Getting the sequence and the defense right is everything.
Why representation matters here
The TFRP is decided largely on facts and characterizations — your role, authority, knowledge, and intent. How those facts are gathered and presented to a Revenue Officer or Appeals can be the difference between personal liability and none. This is not a place to respond to Letter 1153 with a casual letter.
Our process
A case evaluation of the 941 balances and any Letter 1153 / Form 2751; stabilizing where assessment or collection is imminent; building the responsibility/willfulness defense; negotiating and resolving for the business and any personal liability; and follow-through.
This describes how a process works, not a promised result. Outcomes depend on each taxpayer's facts and are not typical or guaranteed.
