Payroll Tax Train-Wreck: Resolving Your Client’s Payroll Tax Nightmare

Author: Eric L Green

CPE Credit:  2 hours for CPAs
2 hours Federal Tax Related for EAs and OTRPs
2 hours Federal Tax Law for CTEC

How to Help Your Small Business Clients Dig Out of the Payroll Tax Hole
The number one reason why small businesses end up in IRS Collection is due to payroll tax liabilities. Best described as the “easiest loan to take and the hardest to pay back,” payroll taxes represent nearly 75% of all revenues into the United States Treasury, and therefore an issue of utmost importance to the IRS. Hence the IRS has become much more aggressive in its plan to close this collection gap, including increased criminal enforcement for unpaid payroll taxes. The impact of the IRS's increased enforcement activities is to send more taxpayers scrambling for professional help in resolving their IRS problems. Payroll tax problems can send a business spiraling into bankruptcy and create personal liabilities for business owners and responsible parties.

The key success factor in assisting businesses and business owners with their payroll tax issues is understanding the rules of how the IRS Collection Division works, how IRC Section 6672 functions, and knowing where the opportunities are to resolve the matter. This practical two-hour CPE course led by attorney Eric L. Green will also review the IRS’s use of the Department of Justice to force businesses to deposit or close, as well as the latest criminal tax enforcement cases for unpaid payroll taxes.

Publication Date: February 2022

Designed For
All CPAs, EAs, and tax professionals who work with clients on business and personal tax issues.

Topics Covered

  • Payroll tax delinquency--how does it work?
  • Personal liability for payroll taxes and who is responsible
  • IRC Section 6672
  • How does the Department of Justice become involved in payroll tax cases
  • Criminal liability for payroll tax delinquencies
  • Best practices for resolving payroll tax issues

Learning Objectives

  • Describe how to outline the steps to resolving payroll liabilities
  • Recognize how to explain the trust tax concepts of personal liability for responsible parties
  • Identify how to develop a strategy for getting a payroll tax client current and compliant
  • Identify the penalty with respect to trust funds
  • Recognize which form is used as an offer in compromise (doubt as to liability)
  • Identify which referenced company falsely represented to its clients that it paid all of the taxes owed


Instructional Method

NASBA Field of Study
Taxes (2 hours)

Program Prerequisites
A basic understanding of payroll taxes and IRS procedures.

Advance Preparation

Registration Options
Regular Fee $62.00

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