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

Payroll, In May of the current year, your employer received a PIER report f...

In May of the current year, your employer received a PIER report from the CRA that identified Canada Pension Plan (CPP) contribution deficiencies for employees in the organization

Calculate nominal interest rate, You have been offered a unique investment ...

You have been offered a unique investment opportunity today; you will receive $500 one year from now. If you invest $10,000 today, you will receive $500 one year from now, $1500 tw

Compute the cost of external equity, Suppose a company issues common stock ...

Suppose a company issues common stock to the public for $25 a share. The expected dividend is $2.50 per share and the growth in dividends is 8%. If the flotation cost is 10% of the

Corporations, C corporation versus S corporation

C corporation versus S corporation

Collective investment fund, A fund that is managed by a trust company or a ...

A fund that is managed by a trust company or a bank and deals with pooled collection of trust accounts. Collective investment funds combine together the assets of several individua

Flow throw entity, For purposes of this problem, ignore the possibility tha...

For purposes of this problem, ignore the possibility that there might be a disguised sale, assume that DEF uses the traditional method for making § 704(c) allocations, and finally

Describe how your  firm creates value, Describe how your  firm creates valu...

Describe how your  firm creates value: Q: a. Dividends are tangible. Unrecognized capital gain is paper money. So, Dividends are always preferable to no payouts by the firm. Di

Justify the present budget deficit, Question 1: i) What is a public goo...

Question 1: i) What is a public good? Discuss how the free rider problem might be a problem in the provision of a public good. ii) What do we mean by ‘‘market failure''? Exp

.calculate the semi annual interest payments, 1. a company issues $10,000, ...

1. a company issues $10,000, 10%, 5 year bonds with semi annual payments principal amount, face value matuity value or par value: $10,000 stated or contract interest rate: 10% (per

Income tax return, "The $3,600 of property taxes for the house were prorate...

"The $3,600 of property taxes for the house were prorated with $1,950 being apportioned to the seller and $1,650 being apportioned to the buyer. In December of the current year the

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