Payroll Tax Problems
Protect Your Business and Personal Assets from IRS Payroll Tax Enforcement
Payroll tax problems are among the most serious issues a business owner can face. The IRS treats payroll taxes — money withheld from employee paychecks — as a special trust obligation. When these funds go unpaid, the IRS moves aggressively to collect from the business and, when necessary, from individual owners and responsible parties personally. Our attorneys have resolved hundreds of payroll tax cases and know exactly how to stop collections, negotiate resolution, and protect personal assets.
What Are Payroll Tax Problems?
Payroll taxes include federal income tax withholding, Social Security, and Medicare taxes (FICA) that employers are required to withhold from employee wages and remit to the IRS on a regular schedule (Form 941). When a business fails to remit these funds — whether due to cash flow problems, administrative errors, or financial distress — the IRS classifies the withheld portion as a "trust fund" because the money legally belongs to the employees and the government. Payroll tax delinquency triggers rapid IRS escalation including federal tax liens, bank levies, and the Trust Fund Recovery Penalty (TFRP) — which can make business owners personally liable for the employee portion of unpaid taxes.
How It Works
Immediate Assessment
We pull your IRS account transcript, identify all delinquent periods, calculate total exposure (including the trust fund portion), and assess personal liability risk immediately.
Stop Active Collections
We contact the IRS to halt any active levies on business bank accounts, negotiate a collection hold, and prevent the seizure of business assets while we work toward resolution.
TFRP Investigation Defense
If the IRS is investigating who is personally responsible for unpaid payroll taxes, we represent you in the interview process and work to limit or eliminate personal liability exposure.
Compliance & Filing
We ensure all delinquent Form 941 returns are filed correctly and that the business is current on future payroll deposits going forward — a prerequisite for any resolution.
Negotiate Resolution
We negotiate an installment agreement, OIC, or other resolution based on the business's ability to pay — often securing a payment plan that keeps the business operating while satisfying the IRS.
Who Should Consider This?
- ✓Business owners with delinquent 941 payroll tax deposits
- ✓Business owners under investigation for the Trust Fund Recovery Penalty
- ✓Closed businesses with outstanding payroll tax obligations
- ✓New owners who acquired a business with inherited payroll tax debt
- ✓Individuals named as responsible parties in a TFRP assessment
- ✓Any employer who has received IRS Notice CP162, CP521, or a Revenue Officer visit
Key Benefits
Keep Your Business Open
Early intervention prevents business closure from bank levies and seizures — we stop collections before they become irreversible.
Protect Personal Assets
Limiting or eliminating TFRP personal liability protects your home, savings, and personal finances.
Structured Repayment
We negotiate payment plans that account for your business cash flow, not just the IRS's preferred collection schedule.
Rapid Response
Payroll tax cases escalate quickly. We respond immediately to stop the damage.
Ready to Resolve Your Payroll Tax Problems Issue?
Free consultation. No obligation. A licensed tax attorney will call you within 5 minutes.
Frequently Asked Questions
Can the IRS hold me personally liable for my company's unpaid payroll taxes?+
Yes. The Trust Fund Recovery Penalty allows the IRS to assess personal liability against any individual they determine was a "responsible party" who "willfully" failed to ensure payroll taxes were remitted — even if the business is closed or bankrupt.
What is the Trust Fund portion of payroll taxes?+
The "trust fund" portion is the employee share of Social Security, Medicare, and income tax withholding. This is the amount the IRS prioritizes for personal collection because it was technically held in trust for the employees and government.
My business is closed. Am I still liable?+
Yes. Business closure does not eliminate payroll tax obligations or personal liability under the TFRP. The IRS can and does pursue former officers and owners for years after a business closes.
How do I respond to an IRS Revenue Officer visit?+
Do not answer questions without representation. Revenue Officers are authorized collectors with significant enforcement powers. Call us immediately — we will contact the Revenue Officer on your behalf.
Related Services
Trust Fund Recovery Penalty
When a business fails to remit payroll taxes, the IRS can hold individual owners and managers personally liable. We fight to protect you.
Installment Agreement
Establish a formal monthly payment plan with the IRS to satisfy your tax debt over time and stop collection actions.
Offer in Compromise
A government-approved program that lets qualifying taxpayers settle their IRS debt for a fraction of the full amount.