Trust Fund Recovery Penalty

The recent Tax Court decision in Woodley v. Commissioner, T.C. Memo. 2017-242, demonstrates the hazards of trust fund recovery penalties (TFRPs) for taxpayers.  A TFRP is a penalty imposed by section 6672(a) on anyone who is responsible for paying payroll taxes but who willfully fails to do so.  Generally, the TFRP is the amount