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

Calculate the tax under capital cost allowance, Your firm  purchased a line...

Your firm  purchased a line of computer equipment for $1.5M  four  years ago.  It is assigned a CCA rate of 20% and the firm has a tax rate of 35%.  At the end of this year (year 4

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

Calculate income tax for company, Microrax Company earned before-tax income...

Microrax Company earned before-tax income of $960,000 for its 2013 fiscal year. During the year the company experienced a $605,000 loss from earthquake damage that it considered to

Fiduciary income calculation and other relevant calculations, fiduciary inc...

fiduciary income calculation and other relevant calculations. Jack Green established the Jackson Trust by a gift in 1999. The trust instrument requires that the trustee (Fifth-Four

, Ken, a resident, is a handyman who contracts with people to do a variety...

Ken, a resident, is a handyman who contracts with people to do a variety of jobs including repairing fences, fixing household items and small painting jobs. As part of this work, K

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

Uganada revenue authority, write a program on Uganda revenue authority tax...

write a program on Uganda revenue authority taxation based on import and export cargo.

How much cash did a firm collect from its customers, Q. How much cash did a...

Q. How much cash did a firm collect from its customers, given the following fact set?  Beginning and ending accounts receivable were $50 and $60, respectively.  Beginning and endin

Explain the characteristics of an efficient tax system, Question 1: (a)...

Question 1: (a) Why does Government intervene in the market's allocation of resources even if the economy is Pareto efficient? (b) What are the principal reasons why marke

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