Son loses IRS letter, taxpayer gets chance to dispute trust fund recovery penalty

06/2/2013 | JournalofAccountancy.com

A taxpayer successfully argued in Tax Court that he never received a trust fund recovery penalty letter from the Internal Revenue Service when his adult son signed for the letter and tossed it in the basement. The Tax Court held that while the IRS could assess the penalty because it sent the letter to his address, the taxpayer's lack of actual receipt meant he could still dispute the underlying liability.

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