IRM Interim Guidance: Payroll Tax Deferral Impact to Collection of Trust Fund Recovery Penalty (IRC §6672)

Revision to Internal Revenue Manual 5.7.3, 5.7.4, 5.7.6 that would implement a temporary deviation to provide guidance to Field Collection employees working Trust Fund Recovery Penalty (TFRP) cases impacted by the CARES Act and Notice 2020-65, as modified by Notice 2021-11, the IRS released December 30. Effective January 4, 2022, the IRS will postpone assessment of the TFRP until after January 3, 2023, on an affected tax period and on any tax period in which the employer was eligible to defer the employer portion of social security tax under Section 2302 of the CARES Act unless: (1) an exigent circumstance ...