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

, 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

What is taxable gift in the year, Wes and Donna were the only members of an...

Wes and Donna were the only members of an LLC, and they fended off unwated takeover suitors with a clause in the charter that shares could change hands only with unanimous approval

Business purpose test, Assume that Zorn received only $24,000 salary during...

Assume that Zorn received only $24,000 salary during the period October 1 through December 31, 2013. What would be the consequences to Zorn, Inc.?

Taxable income for the year, Avis's taxable income for the year is $300,000...

Avis's taxable income for the year is $300,000 and Best's taxable income for the year is $425,000. For each of the scenarios provided, (a) state if a control group has been created

Managing dicrete assignment, Ask qmanaging dicrete assignmentuestion #Minim...

Ask qmanaging dicrete assignmentuestion #Minimum 100 words accepted#

Income tax project, Facts Valerie Lawson and Clara Norman are the sole ...

Facts Valerie Lawson and Clara Norman are the sole equal shareholders in the corporation of Lawson And Norman Enterprises, Inc.  The corporation, which is a retail office suppl

Estate Freeze, Exhibit Additional information • Andy currently owns all of ...

Exhibit Additional information • Andy currently owns all of the shares of Grand Inc., a CCPC with 1,000 common shares issued and outstanding. Grand Inc. operates an active business

Compute the effective income tax rate for 2013 and 2014., The following ite...

The following items caused the only differences between pretax financial income and taxable income. • In 2013, the company collected $90,000 of rent; of this amount, $30,000 was ea

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