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

Individual taxation, #queTonya had the following items for last year: Salar...

#queTonya had the following items for last year: Salary $40,000 Short-term capital gain 12,000 Nonbusiness bad debt (25,000) Long-term capital gain 8,000 For the current year, Tony

Statements on Standards for Tax Services, 28) Explain how Treasury Departme...

28) Explain how Treasury Department Circular 230 differs from the AICPA’s Statements on Standards for Tax Services.

Trusts, how are trusts considered a tax minimisation vehicle?

how are trusts considered a tax minimisation vehicle?

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

Partnership, Ask question #Minimum 100 words ac5) ABLE, inc. and The CAPITA...

Ask question #Minimum 100 words ac5) ABLE, inc. and The CAPITAL Corporation form a general partnership. Capital provides 90% of the cash. Able provides 100% or the partnerships man

Wct, How to raise an invoice with WCT for Civil construction job

How to raise an invoice with WCT for Civil construction job

What is taxpayer identification number, Q. What is Taxpayer Identification ...

Q. What is Taxpayer Identification Number? Taxpayer Identification Number (TIN) - Any taxable entity or other individual that is required to file a return, statement or any oth

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%

Service tax, there is significant difference between the average service ta...

there is significant difference between the average service tax collection per assessee in Pune zone and the average service tax collection per assessee in the country

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