IRS Trust Fund Recovery Penalty Attorney in Massachusetts
If you are being investigated for unpaid payroll taxes, the IRS may attempt to hold you personally responsible through the Trust Fund Recovery Penalty. This means the IRS can pursue your personal bank accounts, wages, and assets — even if the liability originated from a business.
I represent individuals facing Trust Fund Recovery Penalty investigations and assessments, including disputes over responsibility, willfulness, and personal liability
I work directly with individuals and business owners to represent them during IRS investigations, manage communications, and develop a strategy to protect their financial interests.
Speak directly with an attorney about your situation today.
No obligation. Get clear information about your exposure and options before responding to the IRS.
- Work directly with a tax attorney — not a call center
- Focused on high-risk IRS enforcement cases
- Strategic representation during IRS investigations
I provide IRS Trust Fund Recovery Penalty help throughout Massachusetts, including Boston and Quincy.
What Is the Trust Fund Recovery Penalty?
The Trust Fund Recovery Penalty applies to payroll taxes that were withheld from employees but not paid to the IRS. These funds are considered “trust fund” taxes because they are collected on behalf of the government.
If these taxes are not paid, the IRS may assess the penalty against individuals it determines were responsible and acted willfully.
Why This Penalty Is So Serious
This is not just a business issue — it can become a personal liability.
- The IRS can pursue your personal bank accounts and assets
- Wages may be subject to garnishment
- Business protections do not prevent personal assessment
- More than one individual may potentially be held responsible for the same unpaid trust fund taxes.
Once assessed, the Trust Fund Recovery Penalty becomes a personal tax liability that the IRS can collect from the responsible individual.
Who Can Be Held Personally Liable?
The IRS focuses on two key issues: responsibility and willfulness.
- Business owners and partners
- Corporate officers and directors
- Managers with financial control
- Individuals with authority over payroll or tax decisions
Even individuals without ownership may be targeted if they had sufficient control over financial decisions.
Speak with an attorney before responding to an IRS investigation.
Why You Should Not Handle a TFRP Investigation Alone
The IRS builds its case through interviews and financial analysis. Statements made during the investigation may be used to support assessment of the penalty.
How you respond early in the process can significantly affect the outcome.
A structured approach can help protect your position and avoid strengthening the IRS’s case.
How IRS Trust Fund Recovery Penalty Help Works
1. Case Evaluation
I review your role, authority, and the IRS’s evidence to determine whether you meet the criteria for assessment.
2. IRS Investigation Representation
I represent you during IRS interviews and communications, ensuring your responses are accurate and properly framed.
3. Challenging Responsibility or Willfulness
Where appropriate, I develop arguments and present documentation to challenge the IRS’s position.
4. Resolution of Assessed Liability
If the penalty is assessed, I evaluate available collection and resolution options based on the individual circumstances.
5. Ongoing Compliance
After resolution, I help address related issues such as unfiled tax returns or broader IRS tax relief strategies.
The longer IRS issues remain unresolved, the more limited your options may become.
Why Work With Me
- Work directly with an attorney — not a call center
- Focused on high-risk IRS enforcement matters
- Strategic approach to minimizing personal liability
- Direct communication with the IRS
Related IRS Tax Services
If you are located in the Boston area or South Shore, you can learn more here:
Take Action Now
If you are being investigated for the Trust Fund Recovery Penalty, how you respond early matters. Taking action now may improve your ability to limit or avoid personal liability.
Facing a Trust Fund Recovery Penalty? Contact GMD Tax Law Today
If the IRS is investigating you or has proposed or assessed a Trust Fund Recovery Penalty, contact GMD Tax Law of Massachusetts for a FREE consultation. Attorney Gregory Dzialo can represent you in connection with the TFRP investigation, assessment, and related IRS collection matters. Call 617.237.6347 or email gdzialo@gmdtaxlaw.com.
