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

Tax, Home Cable TV Company, an accrual basis taxpayer, allows its customers...

Home Cable TV Company, an accrual basis taxpayer, allows its customers to pay by the month ($25 each month), by the year ($280 per year), or two years in advance ($540). In Decemb

Advanced Tax, The Madison Restaurant was formed a S corporation at the end ...

The Madison Restaurant was formed a S corporation at the end of last year. Bob Buron, owns 60% of the stock, manages the restaurant. Ray Huges owns the remaining 40% of the stock

Corporate tax – itx 628, Problems for Benchmark HW: There are issues here t...

Problems for Benchmark HW: There are issues here that were not covered in live lecture, but here are some issues that you need to be conscious of when attempting the problems. t

Tax questions, 1.   Don and Harvey began operations as a partnership on Oct...

1.   Don and Harvey began operations as a partnership on October 3, 2010. The company spent $60,500 on organization costs that year. How much can the company deduct in 2010 relatin

Tax file, Carol is a successful physician who owns 100% of her incorporated...

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 office building located

Estimated tax payment, Leonard Anthony Silverman and Janice Marie Silverman...

Leonard Anthony Silverman and Janice Marie Silverman, a married couple, live at 17323 Cheryll Parkway Houston, Texas 77056-3672.  Their home telephone number is (713) 937-5629, hom

Compute section 179 deduction and taxable income, Loni Company paid $ 527,0...

Loni Company paid $ 527,000 for tangible personalty in 2011 and elected to expense $ 500,000 of the cost (the limited dollar amount for 2011). Loni's taxable income before a Sectio

Capital gains tax, Joe Smyth further advises you on the following transacti...

Joe Smyth further advises you on the following transaction - work out the resultant capital gains tax consequences.  Then calculate Joe's net capital gain for the 2010/11 income

Which of the following entities may not use the cash method, Which of the f...

Which of the following entities may not use the cash method of accounting? A partnership with average annual gross receipts in excess of $5 million. A C corporation whose avera

Tax, evaluate the importance of the principal issue litigated in the case i...

evaluate the importance of the principal issue litigated in the case in question using the tax research steps outlined in Appendix A of your text.

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