Case: Taxpayer’s Liability for Taxes, Trust Fund Penalty Proven (E.D. Mich.) (IRC §6201)

Government proved it’s entitled to judgment for taxpayer’s outstanding tax liabilities and trust fund recovery penalties, a district court held. The court stated that the IRS satisfied its burden on the assessed tax liabilities by putting forth a Form 4340 and the IRS agent’s testimony. The taxpayer did not respond to the government’s motion and during discovery plead the Fifth Amendment. The government had proof that Taxpayer was the sole owner of his business and the only person who had signatory authority to show that he directed funds to be paid to other creditors instead of the IRS for the ...