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Leaving Money On The Table And Providing An Incentive Not To Pay -- The Story Of A Flawed Collection Device, Temple K. Fogg
Leaving Money On The Table And Providing An Incentive Not To Pay -- The Story Of A Flawed Collection Device, Temple K. Fogg
T. Keith Fogg
As of September 30, 2007, the IRS had $282-billion of unpaid assessments on its books. Of that amount $58-billion, over 20 percent, represents the unpaid payroll taxes due from employers. The majority of payroll taxes due from employers results from income and social security taxes collected by the employer and held in trust for the government. Internal Revenue Code section 6672 ("6672") gives the government the right to pierce the corporate veil to pursue collection of these payroll taxes. Because it creates personal liability, 6672 can serve as a powerful tool in the fight against the growing tax gap.
Unfortunately, …