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Payroll Tax Problems
Resolve trust fund recovery penalties and payroll tax delinquencies.
Talk To A Real Tax Attorney
One honest conversation. You'll hang up knowing exactly what the IRS can — and can't — do to you, and how we'll stop them.
Call (877) 829-5267Tax Attorney · Villanova University School of Law · Admitted in Delaware, New Jersey, United States Tax Court
The Truth About Payroll Tax Problems — And What To Do Right Now
Payroll tax debt is one of the most serious tax problems a business can face. The IRS considers unpaid payroll taxes — money withheld from employees' paychecks — to be essentially stolen from the government. They pursue these cases more aggressively than any other type of tax debt.
Under IRC § 6672, the IRS can assess the Trust Fund Recovery Penalty (TFRP) against any "responsible person" — owners, officers, even bookkeepers — making them personally liable for the entire amount.
McCauley Law Offices defends business owners against TFRP assessments and negotiates resolutions for payroll tax debt, including Offers in Compromise and installment agreements.
What Is the Trust Fund Recovery Penalty?
The TFRP is a 100% penalty equal to the trust fund portion of unpaid employment taxes — the income tax withheld and the employee's share of FICA. It can be assessed against any individual the IRS deems a "responsible person," including:
- Business owners and partners
- Corporate officers — CEO, CFO, Controller
- Bookkeepers and payroll managers with check-signing authority
- Board members who had authority over financial decisions
- Anyone who had the duty and authority to collect, account for, and pay the taxes
The IRS can — and routinely does — assess the TFRP against multiple individuals simultaneously. Each person is jointly and severally liable for the full amount.
How We Defend Against TFRP Assessments
- Challenge responsible person status: Not everyone the IRS targets is actually a responsible person. We gather evidence showing you lacked the authority or control the IRS alleges.
- Fight willfulness: If you were following orders from a superior, were misled by a partner, or didn't have knowledge of the non-payment, you may have a defense.
- Negotiate the amount: Even if liability can't be eliminated, we can often negotiate an Offer in Compromise or installment agreement on the penalty amount.
- Allocate liability: When multiple responsible persons exist, we work to ensure the IRS pursues all parties — not just our client.
People Just Like You Have Sat In This Exact Chair
They were terrified. They were ashamed. They thought they were the only one. Then they made one phone call — and everything changed.
Restaurant Owner with $182,000 in Payroll Debt
A Philadelphia restaurant owner fell behind on payroll taxes during COVID. The IRS assessed $182,000 including trust fund penalties against him personally. We negotiated an Offer in Compromise for $12,500.
TFRP Defended at Form 4180 Interview
A Cherry Hill controller was identified as a potential responsible person for $187,000 in unpaid 941 taxes. We represented her at the Form 4180 interview, established lack of willfulness, and the TFRP was assessed only against the owner.
Business Survival Plan With In-Business IA
A Wilmington restaurant owed $94,000 in 941 taxes and faced imminent shutdown. We negotiated an in-business trust fund installment agreement with full current compliance, the business stayed open, and the balance is on track to be paid.
That Letter In Your Hand? Here's What It Really Means.
The IRS writes notices in code on purpose. If any of these landed in your mailbox, payroll tax problems is exactly how we fight back — and the clock is already ticking.
This is the IRS's first notice telling you that you owe taxes. It shows the amount due, including any penalties and interest.
Deadline: 21 days
This is a final notice before the IRS seizes your assets. They intend to levy (take) your state tax refund and may seize other assets.
Deadline: 30 days
This is the absolute final warning. The IRS will begin seizing your wages, bank accounts, and property within 30 days.
Deadline: 30 days
CP210 (and the related CP220) notifies a business that the IRS has adjusted its tax account — typically a math correction, a credit transfer, or a penalty assessment on a payroll or business return. The notice shows the adjusted balance and may demand additional tax, penalties, and interest.
Deadline: 30 days
Every Day You Wait, The IRS Wins A Little More.
Penalties stack. Interest compounds. Legal options quietly disappear. One free call ends the spiral.
Exactly How We Take This Off Your Shoulders
The hardest step is the first one. Everything after that, we carry for you. No surprises. No runaround. No lectures.
- 1
Get current immediately
No payroll tax resolution works without current compliance. We help you stop the bleeding before negotiating the past.
- 2
Quantify business vs. trust fund exposure
We separate the employer share, trust fund portion, penalties, and interest — the negotiation differs for each component.
- 3
Prepare for the Form 4180 interview
The TFRP determination turns on this interview. We prep every potential responsible person and represent them through it.
- 4
Negotiate the business resolution
In-business installment, partial-pay, or OIC — matched to cash flow and the Revenue Officer's expectations.
- 5
Resolve individual TFRP exposure
Once assessed personally, the TFRP can be addressed with installment, CNC, OIC, or — in some cases — bankruptcy.
Trusted by Thousands of Taxpayers
Real results from real clients
Robert M.
Sandra L.
Michael T.
Jennifer K.
David R.
Maria G.
Thomas W.
Patricia H.
James C.
Robert M.
Sandra L.
Michael T.
Jennifer K.
David R.
Maria G.
Thomas W.
Patricia H.
James C.
Robert M.
Sandra L.
Michael T.
Jennifer K.
David R.
Maria G.
Thomas W.
Patricia H.
James C.
Robert M.
Sandra L.
Michael T.
Jennifer K.
David R.
Maria G.
Thomas W.
Patricia H.
James C.
"McCauley Law resolved my $180,000 IRS debt for a fraction of what I owed. I was facing wage garnishment and bank levies — they stopped everything and negotiated an incredible settlement."
Robert M.
Philadelphia, PA
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The Questions Keeping You Up At Night — Answered
Other Ways We Shut The IRS Down
Offer in Compromise
Settle your tax debt for less than what you owe through IRS settlement programs.
Installment Agreement
Set up manageable monthly payment plans to pay off your tax debt over time.
Currently Not Collectible
Prove financial hardship to temporarily halt IRS collection activity.
Penalty Abatement
Remove or reduce IRS penalties through first-time abatement or reasonable cause.
One Phone Call. Or Another Sleepless Night.
Stop Letting The IRS Own Your Mornings.
You already know what happens if you do nothing. Pick up the phone for a free, confidential conversation with a real tax attorney — 30+ years inside the IRS playbook — and finally start fighting back.
Call (877) 829-5267 NowPrimary Sources & Authority
We cite the underlying IRS publications and statutes so you can verify everything on this page.