Case: Trust Fund Recovery Penalty Subject to Supervisory Approval Requirement, Not Tax (T.C.) (IRC §6672)

Trust fund recovery penalty is a penalty subject to the supervisory approval requirement under tax code Section 6751, Trust Fund Recovery Penalty Letter was sufficient to meet requirements, Settlement officer didn’t abuse discretion in sustaining levy, the U.S. Tax Court held in a division opinion. Separate Revenue officers were assigned to investigate whether Taxpayer was a responsible person for the failure to pay employment taxes on behalf of two LLCs, of which he was the sole member. After it was determined that Taxpayer was a responsible person, each Revenue officer completed a Form 4183, Recommendation re: Trust Fund ...