Reply To: Trust Fund Penalty – Technical Question

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#33330
James Wade
Participant

Eric,

Thank you for the quick reply! Very helpful.

Interesting sidenote. This case was previously a Chapter 13 and interestingly the IRS argued that both debtors were liable for their share separately so instead of allowing (in this case) 100k TFRP and 22k interest (assessed against both of them separately) to be paid 100% through the plan, the IRS objected and required the debtors to treat the debt in the plan as if each owed a separate debt (so doubling it up to 200k priority claim plus interest at 44k). Just goes to show the IRS can’t get this straight all the time either.

Sincerely,

Jim Wade