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

Deductions, Roberta Santos, age 41, is single and lives at 120 Sanborne Ave...

Roberta Santos, age 41, is single and lives at 120 Sanborne Avenue, Springfield, IL 60781. Her Social Security number is 123-45-6789. Roberta has been divorced from her former husb

Calculate the amount of fiduciary income, should be on 2012 forms and done ...

should be on 2012 forms and done in pencil. It should include a schedule that shows the fiduciary income calculation and other relevant calculations. Jack Green established the Jac

Taxation, Alec Smart is 59 years of age and is planning for his retirement....

Alec Smart is 59 years of age and is planning for his retirement. Following a visit to his financial adviser in March of the current tax year, Alec wants to contribute funds to his

Compute cecil''s 2013 federal income tax payable, Pension from former emplo...

Pension from former employer $39,850, Interest income from Alto Nationl Bank 5,500, Interest income on City of Alto bonds 4,500, Dividends received from IBM 2,000, Collection

Capital cost allowance plen limited, On December 1 of the current year, Ple...

On December 1 of the current year, Plen Limited purchased a franchise for $70,000.The franchise has a limited life of 15 years. Which one of the following amount represents the max

Income from salary, Kyle worked as a free-lance software engineer for the f...

Kyle worked as a free-lance software engineer for the first three months of 2013. During that time, he earned $78,000 of self-employment income. On April 1, 2013, Kyle took a job a

Tax shields, T ax Shields A tax shield is defining any reductio...

T ax Shields A tax shield is defining any reduction in a corporation's tax bill which can be brought about by management. Depreciation, for example create a tax shield

Salary, what is the rule of travelling allowance of 2013-14

what is the rule of travelling allowance of 2013-14

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