research assignment, Taxation

Assignment Help:
The following assignment is due the last day of class or at the final exam, in hard copy format only. You may complete the assignment in groups of 2-4, if desired. Indicate your name and group members on a separate cover sheet. You will be graded on accuracy related to the factual question and communication style, clarity and grammar. Your communication should be typed, using white paper, properly titled, double-spaced, with 12-point Times Roman font, and 1 inch margins. Use paragraph breaks as needed for clarity. You do not need to repeat the facts in your communication---only the answer with supporting explanation is required.
FACTS
Lacy Corporation was incorporated in 1983 by Dave Jones, who has served as an officer and member of the board of directors. Mary Smith has served as secretary-treasurer of the company as a convenience to friend Dave. Mary acted as part-time bookkeeper but did not run the everyday business affairs and paid only the bills she was instructed to pay. Mary was an authorized signatory for the corporate bank accounts but had no final control over the expenditures.
Beginning in the last quarter of 2011, the company failed to pay all of the taxes withheld from employees and the employer’s share of FICA taxes to the IRS. Despite this delinquency, the corporation continued to pay other creditors including its employees, in preference to the IRS.
In January 2012, Lacy Corporation entered into an installment agreement with the IRS to keep current on its withholding taxes and to make payments on the past due balance until paid in full. The company subsequently defaulted on the agreement in April 2012. During this period, Dave Jones was serving as chief financial officer and was a member of the board of directors. He had the authority to make policy decisions. He was responsible for negotiating the installment agreement with the IRS and the decision to default on the agreement.
ISSUE
Who is liable for the penalty for nonpayment of the payroll tax withholdings?
Explain your answer in detail 1-2 pages, with research support provided by the following authority. A link is provided for IRC section 6672 and the Carlson case file is provided as a link on D2L.
AUTHORITY
IRC Sec. 6672
https://www.law.cornell.edu/uscode/text/26/6672
Ernest W. Carlson v. U.S. 91-1 U.S.T.C. ¶ 50,262


Related Discussions:- research assignment

Corporate Taxation, 1. L has business assets worth $6,000,000, NOL carryove...

1. L has business assets worth $6,000,000, NOL carryovers of $1,000,000 expiring in 14 years, and NOL carryovers of $1,400,000 expiring in 15 years. 100% of L’s stock is worth $8,

Tax law, Chris married Gina on February 1, 2012, and they became the proud ...

Chris married Gina on February 1, 2012, and they became the proud parents of twins just in time for Christmas. Their Adjusted Gross Income (AGI) for 2012 was $75,000, and their ite

Cumulative software problem, albert''s granfather died and left a portafolo...

albert''s granfather died and left a portafolo of municipal bonds. in 2016, the pay ivan $80.000 in tax-free interest. since the bonds

Prepare a state tax return, David builds and maintains web applications for...

David builds and maintains web applications for a number of clients. He does a majority of his work from his home office, but he frequently drives to the client site to meet with h

Tds , tds late filing fee code & late filing interest code

tds late filing fee code & late filing interest code

Importance of creating a surplus budget, a) Using the above information you...

a) Using the above information you are to construct Fiona's Cash Flow Statement and then explain to her the importance of creating a surplus budget. b) The Net Worth Statement e

Deadweight loss, Suppose there is a negative externality associated with th...

Suppose there is a negative externality associated with the production of aluminum due to the pollution it creates. Is the market quantity of aluminum efficient? Is there a deadwe

Inherentance., Where do I file a person''s life insurance and what they hav...

Where do I file a person''s life insurance and what they have inherited.

Write Your Message!

Captcha
Free Assignment Quote

Assured A++ Grade

Get guaranteed satisfaction & time on delivery in every assignment order you paid with us! We ensure premium quality solution document along with free turntin report!

All rights reserved! Copyrights ©2019-2020 ExpertsMind IT Educational Pvt Ltd