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

Roberta Santos, How much is for the Roberta Santos taxation assignment?

How much is for the Roberta Santos taxation assignment?

Moving expenses deductable?, Just moved out of state. My husband works 3 pa...

Just moved out of state. My husband works 3 part time jobs instead of one full time job. Can we deduct our moving expenses?

Sec 351 of income tax act, Bob and Carl transfer property to Stone Corporat...

Bob and Carl transfer property to Stone Corporation for 90% and 10% of Stone Stock, respectively. Pursuant to a biding agreement concluded before the transfer, Bob sells half of hi

Example of tax file, Research Problem 2: Carol is a successful physician wh...

Research Problem 2: Carol is a successful physician who owns 100% of her incorporated medical practice. She and her husband, Jared, are considering the purchase of a commercial off

Tax liability calculation, Tax Liability Calculation Morgan (age 45) is sin...

Tax Liability Calculation Morgan (age 45) is single and provides more than 50% of the support of Rosalyn (a family friend), Flo (a niece, age 18), and Jerold (a nephew, age 18). Bo

Cumulative catch-up method, Mann Limited purchased machinery  on 1 January ...

Mann Limited purchased machinery  on 1 January 20.9, on which date it was estimated to have a useful life of 5 years and a nil residual value. The carrying amount on 31 December 20

Fringe benefits tax, Mr and Mrs Adams and Mr Adam's mother, Louise, bought ...

Mr and Mrs Adams and Mr Adam's mother, Louise, bought an investment property equally as joint owners in 1979 for $30000. Mr Adams died in 2005. Louise died in 2006. The property wa

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