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The Hidden Tax Trap Of I.R.C. Section 6672, Stephen J. Vasek Jr.
The Hidden Tax Trap Of I.R.C. Section 6672, Stephen J. Vasek Jr.
Law Faculty Scholarly Articles
Two recent decisions of the United States Supreme Court examined section 6672 of the Internal Revenue Code. In Slodov v. United States, the Court expressed its views on the personal liability of business managers for unpaid taxes on employee wages. Discharging such liability because of the personal bankruptcy of the business manager was considered in United States v. Sotelo. The focal point of these cases—section 6672 of the Internal Revenue Code—provides for the potential liability of business managers for the employees’ share of taxes on wages (hereinafter trust fund taxes).
Although Slodov and Sotelo are helpful in understanding …