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Cashaw v. Comm’r, No. 9352-16L, T.C. Memo 2021-123 | October 27, 2021 | Greaves |

Short Summary:  This case involves the application of trust fund recover penalties (“TFRP”) pursuant to I.R.C. § 6672.  The primary issue is whether such penalties were properly assessed against the Petitioner.

Key Issues:

• Whether Petitioner, as temporary chief administrator of Riverside, was individually responsible for TFRPs as a result of Riverside’s failure to remit the full amounts of employment taxes and tax withholdings.
• Whether Petitioner was a “responsible person” under I.R.C. § 6672(a).

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