Document Type

Article

Publication Date

7-2003

Publication Title

Nevada Lawyer

Publication Title (Abbreviation)

Nev. Law.

Volume

11

Issue

7

First Page

24

Last Page

25

Abstract

When collection of unpaid taxes cannot be effected from the person primarily liable for them, the Internal Revenue Code creates for the IRS a number of mechanisms for collection from secondary parties. To satisfy the requirements of fairness and due process, secondary liability is imposed only when the party has some nexus to the liability, that is, when that person's actions helped create the liability or frustrated its collection from the primary taxpayer.

This article discusses l.R.C. § 6672, one of the most widely used and important of the secondary liability mechanisms in tax. There are numerous § 6672 assessments each year. Attorneys representing small business and their owners can expect to have some clients who have § 6672 problems.

Rights

© 2003 Steve R. Johnson

Comments

First published in Nevada Lawyer.

Faculty Biography

http://www.law.fsu.edu/our-faculty/profiles/johnson

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